TD 491 
. A13 
2005 
Copy 2 


V United States 

Environmental Protection 
Agency 


FT MEADE 
GenCol1 


3Ts for Reducing Lead 



Revised Technical Guidance 





UBRARY OF CONGRESS 





Disclaimer 


This manual contains recommendations on how to address lead in school drinking water systems; these are suggestions 
only and are not requirements. This manual does, however, also contain an overview of requirements concerning lead 
in drinking water. The statutory provisions and regulations described in this document contain binding requirements. 
The general description here does not substitute for those laws or regulations; nor is this document a regulation itself. 
As a result, you will need to be familiar with the details of the rules that are relevant to your school drinking water; you 
cannot rely solely on this guidance for compliance information. Also, many states (or tribes) and localities have 
different, more stringent requirements than EPA’s, so you will need to find out what other laws and regulations apply to 
school drinking water in addition to the ones described here. 



3Ts for Reducing Lead in Drinking Water in Schools: 

Revised Technical Guidance 

Jb^/ 

s° ? tents 'i'/u 


Introduction 



4 


I. Training. 6 

1. What You Should Know about Lead in Drinking Water. 6 

1.1 Health Effects of Lead. 6 

1.2 Sources of Lead. 6 

1.3 How Lead Gets into Drinking Water. 7 

1.4 How Lead in Drinking Water is Regulated. 11 

2. Planning Your Program and Establishing Partnerships . 13 

2.1 Assigning Roles. 13 

2.2 School Records. 13 

2.3 Establishing Partnerships. 13 

2.3.1 Assistance from Your Public Water Supplier . 13 

2.3.2 Assistance from Your Local Health Office . 13 

2.3.3 Assistance from Your State Drinking Water Program . 15 

2.3.4 Assistance from Certified Laboratories . 15 

2.3.5 Assistance from Local Community Organizations . 16 


II. Testing. 

3. Assessment and Strategy: Plumbing Profile and Sampling Plan. 

3.1 Development of a Plumbing Profile for Your Facility’s Plumbing. 

3.2 Who Should Create the Sampling Plan? - Leadership in Sampling. 

3.3 Where Should I Sample? - Determining Sample Locations. 

3.4 Who Should Collect the Samples and Where Do Samples Go for Analysis? 

Collection and Analysis of Samples. 


4. 


Conducting Sampling. 

4.1 General Sampling Procedures . 

4.2 Collection Procedures. 

4.3 Laboratory Analysis and Handling of Sample Containers 

4.4 Overview of the Two-Step Sampling Process. 

4.4.1 Step 1: Initial Sampling . 

4.4.2 Step 2: Follow-Up Sampling . 

4.4.3 Initial and Follow-Up Sampling Protocol . 

4.4.4 Sampling for Other Parameters . 



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3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


5. Remedies . 54 

5.1 Routine Control Measures. 54 

5.2 Interim (Short-Term) Control Measures. 54 

5.3 Permanent Remedies. 56 

III. Telling.64 

6. Informing the Public about Lead. 64 

6.1 Techniques for Disseminating Public Information. 64 

6.2 The Components of an Effective General Communication Strategy. 65 

6.3 Participants.65 

6.4 Timing.66 

6.5 Content.66 

6.6 Methods and Manner of Communication. 66 

6.7 Sample Public Notice Materials.67 

Appendix A - Glossary of Terms.72 

Appendix B - Publication List.74 

Appendix C - Resources.76 

Appendix D - List of State Drinking Water Programs.77 

Appendix E - Water Cooler Summary.85 

Appendix F - Sample Recordkeeping Form.88 

Appendix G - Preservation of Samples and Sample Containers.89 

Appendix H - Example Scenarios for Water Sample Results.90 

Appendix I - Plumbing Profile Questionnaire.95 


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3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Exhibits 

Exhibit 1.1: Potential Sources of Lead in Schools .9 

Exhibit 1.2: Common Drinking Water Outlets. 10 

Exhibit 3.1: Sample Plumbing Profile Questionnaire. 18 

Exhibit 3.2: Plumbing Configuration for a Single-Level Building.26 

Exhibit 3.3: Plumbing Configuration for a Multi-Level Building.27 

Exhibit 4.1: Pipe Volumes for Copper Pipe.33 

Exhibit 4.2: Sample Strategy Flowchart.34 

Exhibit 4.3: Service Connection Sampling.36 

Exhibit 4.4: Drinking Water Fountains: Bubblers.38 

Exhibit 4.3: Drinking Water Fountains: Water Coolers.40 

Exhibit 4.6: Drinking Water Fountains: Bottled Water Dispensers.44 

Exhibit 4.7: Ice Making Machines.45 

Exhibit 4.8: Water Faucets (Taps).46 

Exhibit 4.9: Sampling Interior Plumbing.47 

Exhibit 4.10: Sample Sites for a Single-Level Building.52 

Exhibit 4.11: Sample Sites for a Multi-Level Building.53 

Exhibit 5.1: Flushing Directions by Outlet Type.55 

Exhibit 5.2a: Remediation Flow Chart (part 1).59 

Exhibit 5.2b: Remediation Flow Chart (part 2).60 

Exhibit 5.2c: Remediation Flow Chart (part 3).61 

Exhibit 5.3: Case Study 1.62 

Exhibit 6.1: Sample Public Notice Letter.68 

Exhibit 6.2: Sample Press Release for Local Media.69 

Exhibit 6.3: Sample Newsletter Article. 70 



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3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Introduction 


The Environmental Protection Agency (EPA) developed this guidance manual because the Agency is concerned 
about the potential for elevated lead levels in drinking water in schools. Children are most susceptible to the 
effects ol lead, because their bodies are still undergoing development. The adverse health effects from lead 
include reduced IQ and attention span, learning disabilities, poor classroom performance, hyperactivity, 
behavioral problems, impaired growth, and hearing loss. 

There is no federal law requiring testing of drinking water in schools, except for schools that have their own 
water supply and are thus regulated under the Safe Drinking Water Act (SDWA). The vast majority of public 
water suppliers do not include schools in their sampling plans because regulations (specifically the Lead and 
Copper Rule) require sampling of single family dwellings. States and local jurisdictions may, however, 
establish their own programs for testing drinking water lead levels in schools. EPA suggests that schools 
implement programs for reducing lead in drinking water as part of the school’s overall plan for reducing 
environmental threats. Safe and healthy school environments foster healthy children, and may improve 
students’ general performance. 

Lead most frequently gets into drinking water by leaching from plumbing materials and fixtures as water 
moves through your school’s distribution system. Even though the drinking water you receive from your 
water supplier meets federal and state standards for lead, your facility may have elevated lead levels due to 
plumbing materials and water use patterns. Because lead concentrations can change as water moves through 
the distribution system, the best way to know if a school might have elevated levels of lead in its drinking 
water is by testing the water in that school. Testing facilitates an evaluation of the plumbing and helps target 
remediation. It is a key step in understanding the problem, if there is one, and designing an appropriate 
response. 


This guidance manual is intended for use by school officials responsible for the maintenance and/or safety of 
school facilities including the drinking water. The guidance introduces the 3Ts for reducing lead in drinking 
water. The 3Ts are: 


► Training school officials to raise awareness of the potential occurrences, causes, and health 
effects of lead in drinking water; assist school officials in identifying potential areas where 
elevated lead may occur; and establishing a testing plan to identify and prioritize testing sites. 

► Testing drinking water in schools to identify potential problems and take corrective actions as 
necessary. 

► Telling students, parents, staff, and the larger community about monitoring programs, 
potential risks, the results of testing, and remediation actions. 

The purpose of this manual is to help schools minimize their students’ and staff’s exposure to lead in drinking 
water. This manual is specifically targeted at schools that receive water from water utilities or water suppliers 
such as cities, towns and water districts. This guidance manual replaces the 1994 EPA guidance document 
Lead in Drinking Water in Schools and Non-Residential Buildings. By following the steps below, you will be 
assured your facility does not have elevated levels of lead in the drinking water. 


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3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Training 

(1) Conduct a thorough review of this guidance document. Other reference documents are available. See 
Appendix B. 

(2) Review available resources to find out what may already have been done and what assistance may be 
available to you. See Chapter 2. 

(3) Develop a plumbing profile to assess the factors that contribute to lead contamination. See Chapter 3. 

(4) Develop a drinking water sampling plan. See Chapter 3. 

Testing 

(5) Test the water. See Chapter 4. 

(6) Correct any problems that are identified. See Chapter 5. 

Telling 

(7) Communicate to students, parents, staff, and the larger community about what you are doing to protect 
them from possible exposure to lead in drinking water. See Chapter 6. 


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3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


I. Training 


1. What You Should Know about Lead in Drinking Water 


1.1 Health Effects of Lead 

Lead is a toxic metal that is harmful to human health. Lead has no known value to the human body. The 
human body cannot tell the difference between lead and calcium, which is a mineral that strengthens the 
bones. Like calcium, lead remains in the bloodstream and body organs like muscle or brain for a few months. 
What is not excreted is absorbed into the bones, where it can collect for a lifetime. 

Young children, those 6 years and younger, are at particular risk for lead exposure because they have frequent 
hand-to-mouth activity and absorb lead more easily than do adults. Children’s nervous systems are still 
undergoing development and thus are more susceptible to the effects of toxic agents. Lead is also harmful to 
the developing fetuses of pregnant women. 

No safe blood lead level in children has been determined. Lead can affect almost every organ and system in 
your body. The most sensitive is the central nervous system (brain), particularly in children. Lead also 
damages kidneys and the reproductive system. The effects are the same whether it is breathed or swallowed. 
Low blood levels of lead (those below 10 jag/dL) have been associated with reduced IQ and attention span, 
learning disabilities, poor classroom performance, hyperactivity, behavioral problems, impaired growth, and 
hearing loss. Very high lead level (blood lead levels above 70 |ag/dL) can cause severe neurological problems 
such as coma, convulsions, and even death. The only method to determine a child’s lead level is for them to 
have a blood lead test done by a health provider. 

The degree of harm from lead exposure depends on a number of factors including the frequency, duration, and 
dose of the exposure(s) and individual susceptibility factors (e.g., age, previous exposure history, nutrition, and 
health). In addition, the degree of harm depends on one’s total exposure to lead from all sources in the 
environment - air, soil, dust, food, and water. Lead in drinking water can be a significant contributor to 
overall exposure to lead, particularly for infants whose diet consists of liquids made with water, such as baby 
food, juice, or formula. 


1.2 Sources of Lead 

Lead is distributed in the environment through both natural and man-made means. Today, the greatest 
contributions of lead to the environment stem from past human activities. Sources of lead exposure include 
the following: 

(1) Lead based paint. The most common sources of lead exposure for children are chips and particles of 
deteriorated lead paint. Although children may be exposed to lead from paint directly by swallowing 
paint chips, they are more often exposed by house dust or soil contaminated by leaded paint. Lead 
paint chips become ground into tiny bits that become part of the dust and soil in and around homes. 
This usually occurs when leaded paint deteriorates or is subject to friction or abrasion (as on doors and 
windowsills and window wells). In addition, lead can be dispersed when paint is disturbed during 
demolition, remodeling, paint removal, or preparation of painted surfaces for repainting. 


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3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


(2) Lead in the air. Lead in the air comes from industrial emissions. 

(3) Lead in soil. Lead deposits in soils around roadways and streets from past emissions by automobiles 
using leaded gas, together with paint chips and lead paint dust. 

(4) Lead industry. Byproducts brought home by industrial workers on their clothes and shoes. 

(5) Lead in consumer products and food. Lead may be found in some imported candies, medicines, 
dishes, toys, jewelry, and plastics. 

(6) Lead in water. Lead in water occurs through corrosion of plumbing products containing lead. 

The U.S. government has taken steps over the past several decades to dramatically reduce new sources of lead 
in the environment: by banning the manufacture and sale of leaded paint; by phasing out lead additives in 
gasoline, and by encouraging the phase-out of lead seams in food cans; by banning the sale of pipes and 
plumbing lor drinking water that are not “lead-free”; and by banning lead-lined water coolers, among other 
activities. More recently, the government has begun to address persistent sources of lead in the environment. 
For example, programs have been instituted to minimize the hazards posed by lead paint covering millions of 
homes across the United States, more stringent air control standards are being applied to industries emitting 
lead, and more stringent regulations are in place to control lead in drinking water. Regulations affecting lead in 
drinking water are described at the end of this chapter. 


1.3 How Lead Gets into Drinking Water 

Lead can get into drinking water in two ways: 

(1) by being present in the source water, such as coming from contaminated runoff or water pollution. 

(2) through an interaction between the water and plumbing materials containing lead, such as through 
corrosion. 

(1) At the Source 

Most sources of drinking water have no lead or very low levels of lead (i.e., under 3 parts per billion). 
However, lead is a naturally occurring metal and in some instances can get into well water. Lead can enter 
surface waters (waters from rivers, lakes, or streams) through direct or indirect discharges from industrial 
or municipal wastewater treatment plants or when lead in air settles into water or onto city streets and 
eventually, via rain water, flows into storm sewers, or waterways, which may enter the water supply. Lead 
from these sources can be easily removed by existing treatment plant technologies. 

(2) Through Corrosion 

Most lead gets into drinking water after the water leaves the local well or treatment plant and comes into 
contact with plumbing materials containing lead. These include lead pipe and lead solder (commonly 
used until 1986) as well as faucets, valves, and other components made of brass. The physical/chemical 
interaction that occurs between the water and plumbing is referred to as corrosion. The extent to which 
corrosion occurs contributes to the amount of lead that can be released into the drinking water. 

The critical issue is that even though your public water supplier may deliver water that meets all federal and 
state public health standards for lead, you may end up with too much lead in your drinking water because of 
the plumbing in your facility. The potential for lead to leach into water can increase the longer the water 


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3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


remains in contact with lead in plumbing. As a result, facilities with intermittent water use patterns, such 
as schools, may have elevated lead concentrations. Testing drinking water in schools is important 
because children spend a significant portion of their day in these facilities and are likely to consume 
water while they are there. That is why testing water from your drinking water outlets for lead is so 
important. Drinking water outlets are locations where water may be used for consumption, such as a drinking 
fountain, water faucet, or tap. 

The corrosion of lead tends to occur more frequently in “soft” water (i.e., water that lathers soap easily) and 
acidic (low pH) water. Other factors, however, also contribute to the corrosion potential of the water and 
include water velocity and temperature, alkalinity, chlorine levels, the age and condition of plumbing, and the 
amount of time water is in contact with plumbing. The occurrence and rate of corrosion depend on the 
complex interaction between a number of these and other chemical, physical, and biological factors. 

As illustrated in Exhibit 1.1, once the water leaves the public water supply system or treatment plant, drinking 
water comes into contact with plumbing materials that may contain lead. Some lead may get into the water 
from the distribution system — the network of pipes that carry the water to homes, businesses, and schools in 
the community. Some communities have lead components in their distribution systems, such as lead joints in 
cast iron mains, service connections, pigtails, and goosenecks. These components may or may not be owned 
by your water supplier. 

Sediments containing lead may also collect in the low-lying sections of pipe or behind sediment screens. Lead- 
containing sediments may result from minute particles of pipe, mineral deposits (scales), valves, fixtures, 
solder, or flux that accumulate in the plumbing. This may happen during the initial construction of the 
plumbing system, during repairs, when connecting new fixtures, when plumbing is otherwise disturbed, or 
during normal use (e.g., turning of faucet handles, movement of valves, etc.). Sediment can also originate 
from the public water systems water mains and service taps. 

If the public water supplier finds unacceptable levels of lead at customers’ homes, the system may have to 
provide centralized treatment to minimize the corrosion of lead into the water (see “How Lead in Drinking 
Water is Regulated” in section 1.4). However, centralized treatment by a public water system does not 
guarantee that corrosion of lead from plumbing will not occur within buildings served by the public water 
system, i.e., your school. 

Interior plumbing, soldered joints, leaded brass fittings, and various drinking water outlets that contain lead 
materials are the primary contributors of lead in drinking water. It is also important to note that brass 
plumbing components contain lead. Examples of some of the common drinking water outlets are shown in 
Exhibit 1.2. (The glossary in Appendix A provides definitions of the various drinking water outlets discussed 
in this document.) Although there is an increased probability that a given plumbing component installed 
prior to the 1990s could contain more lead than the newer components, the occurrence of lead in drinking 
water can not be predicted based upon the age of the component or the school facility. 


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3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Exhibit 1.1: 


Potential Sources of Lead in Schools 



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3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Exhibit 1.2: Common Drinking Water Outlets 


Lateral 

Pipe 



Connecting 

Pipe 


Solder 

Joint 


Cooling Element 2 


Water Cooler 




1 Valve locations are approximate and will vary, depending upon installation. 

2 Old cooling elements may be lead-lined. For more information on replacement of lead-lined cooling 
elements, see Appendix E of this document. 


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3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


1.4 How Lead in Drinking Water is Regulated 

Lead is regulated in public drinking water supplies under a federal law known as the Safe Drinking Water Act 
(SDWA). This Act was initially passed in 1974 and, in part, requires EPA to establish regulations for known 
or potential contaminants in drinking water for the purpose of protecting public health. 

The requirements developed by EPA apply to public water systems. Schools that are served by a public water 
system (i.e., a drinking water system that they do not own or operate) are not subject to the SDWA 
monitoring and treatment requirements, because those schools do not meet the definition of a public water 
system. However, some states may have monitoring and treatment requirements for these schools. Nearly all 
states have a drinking water office that implements the SDWA on behalf of EPA. Questions regarding the 
regulation of your drinking water may be directed to the appropriate state drinking water program office (see 
Appendix D for a directory of state programs). 

Additional requirements under the Safe Drinking Water Act include specific provisions for controlling lead in 
drinking water: 

► THE LEAD BAN (1986): A requirement that only lead-free materials be used in new plumbing and 
in plumbing repairs. 

► THE LEAD CONTAMINATION CONTROL ACT (LCCA) (1988): The LCCA fiirther 
amended the SDWA. The LCCA is aimed at the identification and reduction of lead in drinking 
water at schools and child care facilities. However, implementation and enforcement of the LCCA has 
been at each state’s discretion. School monitoring and compliance has varied widely. 

► THE LEAD AND COPPER RULE (1991): A regulation by EPA to minimize the corrosivity and 
amount of lead and copper in water supplied by public water systems. 

The table below summarizes the significant elements of the SDWA with respect to lead in drinking water. 
Note that the 1991 Lead and Copper Rule does not apply to schools that receive water from a public water 
system. 


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3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Requirements Under the Safe Drinking Water Act 

• The 1986 SDWA Lead Ban. This provision of the SDWA requires the use of "lead-free" pipe, solder, and flux in 
the installation or repair of any public water system or any plumbing in a residential or non-residential facility 
providing water for human consumption. Solders and flux are considered to be lead-free when they contain less 
than 0.2 percent lead. Before this ban took effect on June 19, 1986, solders used to join water pipes typically 
contained about 50 percent lead. Pipes and pipe fittings are considered "lead-free" under the Lead Ban when 
they contain less than 8 percent lead. Plumbing fixtures that are not "lead-free" were banned from sale after 
August 6, 1998. Plumbing fixtures are subject to the NSF International standard. 

NOTE: "Lead-free” pipe is allowed to contain up to 8 percent lead and "lead-free" solder and flux may 
contain up to 0.2 percent lead. Lead-free plumbing components are not necessarily "free" of lead. 

• The 1988 Lead Contamination Control Act (LCCA). The purpose of the LCCA is to reduce lead exposure 
and the health risks associated with it by reducing lead levels in drinking water at schools and child care centers. 
The LCCA created lead monitoring and reporting requirements for all schools, and required the replacement of 
drinking water fixtures that contained excessive levels of lead (see Appendix E for a listing of these fixtures). The 
provisions are not enforceable. As a result, states have the option to voluntarily enforce the provisions of the Act 
(or alternate provisions) through their own authority. 

• The 1991 Lead and Copper Rule (LCR). The LCR requires public water suppliers to monitor for lead in 
drinking water and to provide treatment for corrosive water if lead or copper are found at unacceptable levels. 
EPA strongly recommends that schools test their facilities for lead. However, unless a school owns its water 
system, testing for lead and copper within the school is not specifically required. Therefore, many schools served 
by water systems owned by cities, towns, or other entities may have never been tested for lead under the LCR. 


Public Water Supply Testing vs. Testing at Schools 

(1 5 ppb vs 20 ppb) 

• It is important to note that the lead testing protocol used by public water systems is aimed at identifying 
system-wide problems rather than problems at outlets in individual buildings. Moreover, the protocols for 
sample size and sampling procedures are different. Under the LCR for public water systems, a lead action level 
of 15 parts per billion (ppb) is established for 1 liter samples taken by public water systems at high-risk 
residences. If more than 10 percent of the samples at residences exceed 15 ppb, system-wide corrosion control 
treatment may be necessary. The 15 ppb action level for public water systems is therefore a trigger for 
treatment rather than an exposure level. 

• EPA recommends that schools collect 250 mL first-draw samples from water fountains and outlets, and that the 
water fountains and/or outlets be taken out of service if the lead level exceeded 20 ppb. The sample was designed 
to pinpoint specific fountains and outlets that require remediation (e.g. water cooler replacement). The school 
sampling protocol maximizes the likelihood that the highest concentrations of lead are found because the first 
250 mL are analyzed for lead after overnight stagnation. 


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3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


2. Plan nin g Y our Progra m and Establishing Partnerships 


Monitoring for lead in your school’s drinking water is extremely important. If you have never or have not 
recently monitored for lead in your school’s drinking water, you are encouraged to begin the process by 
identifying any lead problems that you may have in your drinking water. You should start by identifying your 
existing resources, which include school records, available finances, and personnel. You should also research 
opportunities for assistance from your local public water supplier, state and local health agencies, and certified 
water testing laboratories. 


2.1 Assigning Roles 

Your school should assign responsibility to a key individual(s) to ensure that testing and follow-up actions are 
completed. A person should also be appointed to serve as the contact person for communication with 
interested parties (civic groups, the media, etc.). One person or more may be involved in these activities, but it 
is important to clearly define responsibilities and to support those people in their roles. An effective program 
will require a team effort. 

If your school decides to use consultants or lab personnel, their roles should be defined with respect to the 
responsible person(s) at the school. Contact your state drinking water program or local health department if 
you need advice on how to identify a qualified consultant. 


2.2 School Records 

To determine if previous monitoring efforts have been made at your school, you should review your school 
records. Some schools conducted voluntary monitoring in cooperation with state or local officials in response 
to the 1988 Lead Contamination Control Act (LCCA). Other schools may have sampled for lead in response 
to state requirements. This information will be useful in filling out your Plumbing Profile Questionnaire (see 
Chapter 3), a tool that may be used to help determine whether lead is likely to be a problem in your facility. 
Records should also be reviewed to determine whether remediation actions have been taken. For example, 
have water coolers that contain lead been replaced (see Appendix E for a listing of banned water coolers)? 
While these records may not make additional testing or remediation unnecessary, they will help to prioritize 
your efforts and make them more efficient. 

If testing or remediation was conducted in response to the 1988 Lead Contamination Control Act, it may 
have taken place 10 years ago or more. If you are not familiar with what activities may have taken place at 
your school and your records are incomplete or absent, you are encouraged to contact individuals that may 
have been involved in the past. Personnel that were involved may remember activities that were not well- 
documented. They may also remember whether other agencies or the local public water supplier were 
involved, which may mean that additional records are available. 


2.3 Establishing Partnerships 

2.3.1 Assistance from Your Public Water Supplier 

Some public water suppliers have devoted resources to helping schools conduct testing for lead even though 
they may not be legally required to do so. As discussed in the previous chapter, public water suppliers are 


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3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


required by the Lead and Copper Rule to monitor for lead at customers’ taps. However, testing at schools 
was not specifically required unless the public water system was owned and operated by the school. 

Therefore, unless a school served by a public water system tested for lead on its own, or had testing 
voluntarily conducted by the public water system, neither the school nor the public water system is likely to 
have any record of testing. Although the public water system may treat the water to minimize corrosion, it is 
very important that you test to determine to what extent lead is leaching from plumbing within the school. 

You are encouraged to contact your public water supplier to determine whether assistance or information on 
previous efforts is available. Although utilities are under no obligation to do so, assistance may be available 
through technical guidance, sampling, or sharing in sampling costs. Some utilities may be willing to help 
develop sampling plans (see Chapter 3) and plumbing profiles (see Chapter 3). The American Water Works 
Association (AWWA), a non-profit organization of water system professionals, recently prepared a summary 
of information for water suppliers on options for providing assistance to schools. 

You should obtain the results of your water supplier’s required monitoring under the Lead and Copper Rule 
to determine whether they are in compliance with the requirements of the Lead and Copper Rule. Your 
water utility should be able to tell you whether lead monitoring is current, whether the monitoring results are 
below the lead action level, and whether corrosion control treatment is provided. Your water supplier should 
also be able to tell you whether they have conducted lead monitoring at your school, and they may be able to 
give you some indication of whether lead could be a problem within your building(s). 

You may wish to begin by contacting your local director of public works, water superintendent, or water 
department, depending upon how your utility is organized. Some utilities have Web sites with contact 
information. All public water suppliers are required to produce and distribute an annual Consumer 
Confidence Report (CCR). You may want to get in the habit of thoroughly reviewing your utility’s CCR for 
important information about the water chemistry and overall water quality. Changes in water chemistry or 
quality may affect your school’s long-term sampling plan. The CCR also provides the name(s) and contact 
information for those at your utility who may be able to answer any questions you have. 


Questions to Ask Your Drinking Water Supplier 

It is important to know who supplies your facility's drinking water, and whether and how the water entering your 
facility is treated. Some kinds of treatment can make the water more corrosive, while others will reduce the problem. 
If the water is corrosive, treatment can reduce lead levels throughout the system and can save you and the supplier 
money by reducing damage to plumbing. The following are some questions you may want to ask your public water 
supplier: 

• Ask for a copy of the most recent annual water quality report (CCR). 

• Is the water system in compliance with federal and state standards for lead monitoring and treatment? 

• What steps have been taken to maintain compliance with the Lead and Copper Rule? 

• Does the utility have sample results from the school? 

• Is the water corrosive? If so, what is the system doing to minimize corrosion? 

• If a corrosion control chemical is used, does the chemical form a protective coating inside the piping? 

• Does the water distribution system have any lead piping (for example, lead gooseneck at service connections), 
and does the system plan to remove these sources of lead? 


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3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


2.3.2 Assistance from Your Local Health Office 

Many local governments have established programs that are responsible for a wide variety of public health 
protection activities, such as a Lead Poisoning Prevention Program. These programs are often the first line of 
defense when public health risks arise. Lead programs for children are often a high priority for local health 
offices. 

You may wish to contact the local health office to discuss your needs. Although resources may be limited, the 
office may be willing to provide assistance in a variety of ways. For example, a representative may be able to 
attend Parent and Teacher Association meetings to discuss potential health effects, as well as to act as a contact 
with state programs to obtain information and assistance. A representative may even be able to assist in 
developing the plumbing profile, conducting sampling, or in taking follow-up action. 

The phone number for your local health office should be in the listings under your county or city 
government. Many offices also have a Web site. The following Web site contains information about many 
local health departments listed by state http://www.healthguideusa.org/local health departments.htm. 

2.3.3 Assistance from Your State Drinking Water Program 

As discussed in Chapter 1, the only federal requirement that applies uniformly to schools that receive water 
from a public water system is the ban on the installation of water system components that are not lead-free 
(the Lead Ban). 

You are encouraged to contact your state program to determine whether any other requirements apply, or 
whether technical assistance is available. The drinking water program may be housed in the department of 
health or the department of the environment. A listing of state program contacts is contained in Appendix D. 
Most state programs also have Web sites with contact information. The following Web site contains 
information about many state health departments 

http://www.healthguideusa.org/state health departments.htm. When discussing the issue with your state 
program, you may wish to request assistance with voluntary compliance with the Lead Contamination 
Control Act. Since most state programs are familiar with the Act, this should help to clarify your request. 

If you have not been able to make contact with your local public water supplier, you may also wish to ask 
whether the state program can provide information on monitoring compliance, results, and treatment. Your 
state program regulates all such water suppliers for compliance with the Lead and Copper Rule, and therefore 
should have this information readily available. 

You may also wish to ask the state drinking water program staff about other state programs that are involved 
in reducing lead risks for children. There may be an interest in developing a cooperative effort between state 
programs or between state and local agencies. 

2.3.4 Assistance from Certified Laboratories 

Your state drinking water office should be able to provide a list of certified laboratories in your area. You 
should only use a laboratory that is certified by the state or EPA for testing lead in drinking water for public 
water systems. 

Some laboratories will provide assistance in addressing the activities described in this manual. For example, 
some laboratories will collect samples for clients to ensure proper sampling technique and sample preservation. 
However, costs for services will vary and you may wish to contact several certified labs. 


15 






3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


If outside laboratory personnel are used, you should ensure that they understand the testing procedures 
described in this manual because these procedures differ from those used by public water suppliers for 
compliance with the Lead and Copper Rule. 

2.3.5 Assistance from Local Community Organizations 

Your community has a variety of local organizations that can help; for example community volunteer groups, 
senior citizens groups, the Parent and Teacher Associations, and local environmental groups. Tap into the 
expertise of people in your community who may be able to help with all aspects of your lead in drinking water 
reduction program. Another useful resource is your region’s Pediatric Environmental Health Speciality Unit 
(PEHSU). Your region’s PEHSU may be able to provide risk communication support to school districts; for 
more information please visit http://www.aoec.org/PEHSU.org . 

Contacting these groups is another way for your school to foster support. These groups might be willing to 
volunteer time to collect samples and train others to collect samples. 


16 









3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


II. Testing 

3. Assessment and Strategy: Plumbing Profile and Sampling Plan 


3.1 Development of a Plumbing Profile for Your Facility's Plumbing 

Before testing and correcting lead problems, it is important to target potential problems and to assess the 
factors that can contribute to lead contamination and the extent to which contamination might occur in your 
facility. You can best accomplish these objectives by developing a plumbing profile of your facility. If your 
facility has additions, wings, or multiple buildings built during different years, a separate plumbing profile 
may be recommended for each. A plumbing profile can be created by answering a series of questions about 
your facility’s plumbing. Every school is unique and a plumbing profile will help you understand the 
potential sources of lead in your facility. Conducting this survey of your facility’s plumbing will enable you 
to: 

• Understand how water enters and flows through your building(s). 

• Identify and prioritize sample sites. EPA recommends the following sites as priority sample sites: 
drinking fountains (both bubbler and water cooler style), kitchen sinks, classroom combination sinks 
and drinking fountains, home economics room sinks, teachers’ lounge sinks, nurse’s office sinks, sinks 
in special education classrooms, and any other sink known to be or visibly used for consumption (e.g., 
cofifeemaker or cups are nearby). 

• Understand whether you may have a widespread contamination problem or only localized concerns. 

• Plan, establish, and prioritize remedial actions, as necessary. 

Exhibit 3.1 provides a plumbing profile questionnaire discussion and interpretations of possible answers 
designed to help you plan your testing strategy and develop your sampling plan. Planning your strategy will 
enable you to conduct testing in a cost-efficient manner. For a blank copy of the plumbing profile 
questionnaire, see Appendix I. 


17 







Exhibit 3.1: Plumbing Profile Questionnaire 


3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 



18 











3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 











3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 



20 













3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 



21 







3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 



22 












3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 



23 










3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Now that you understand the potential dangers of lead contamination in drinking water and the laws and 
programs in place to address this problem, it is time to begin development of a plumbing profile and a 
sampling plan. 


3.2 Who Should Create the Sampling Plan? - Leadership in Sampling 

As discussed in Chapter 2, it is important to designate a school employee(s) to take responsibility of the 
sampling program and follow-up activities, even if someone else is hired to conduct testing. II laboratory 
representatives or consultants are used to conduct testing, you should ensure that they have experience in 
conducting lead testing at schools. You may wish to ask the laboratory or consultant for references. Contact 
your state or local health department or drinking water program if you need advice on how to identify a 
qualified consultant. 


3.3 Where Should I Sample? - Determining Sample Locations 

You must decide where to take samples and how to prioritize the sample sites based on your responses to the 
plumbing profile and your knowledge of the facility. If possible, every outlet used for drinking or cooking 
should be sampled. At a minimum , every outlet that is regularly used for cooking and drinking should be 
sampled. Sample sites that are most likely to have lead contamination include: 

• Areas containing lead pipes or lead solder. 

• Areas of recent construction and repair in which materials containing lead were used. 

• Areas where the plumbing is used to ground electrical circuits. 

• Areas of low flow and/or infrequent use. 

• Areas containing brass fittings and fixtures. 

• Water coolers identified by EPA (See Appendix E) as having lead-lined storage tanks or lead parts. 
These should be removed. 

It may be helpful to diagram the plumbing in your facility and the outlets that will require testing. Examples 
of plumbing configurations for a single-level building and a multi-level building are illustrated in Exhibits 3.2 
and 3.3, respectively. Locate service connections, headers, laterals, loops, drinking water fountains (bubblers 
and coolers), riser pipes and different drinking water loops (see Appendix A for a glossary of these plumbing 
terms), and decide in what order you wish to take samples. 

As shown in the above-mentioned Exhibits, water is carried to the different floors in a multi-level building by 
one or more riser pipes. Water from the riser pipes is usually distributed through several different drinking 
water loops. In addition, in some buildings, water may be stored in a tank prior to distribution. In single¬ 
story buildings, the water comes from the service connection via main plumbing branches, often called 
headers. These, in turn, supply water to laterals. Smaller plumbing connections from the laterals and loops 
supply water to the faucets, drinking water fountains, and other outlets. For sampling purposes, water within 
a plumbing system moves “downstream” from the source (i.e., from the distribution main in the street 
through the service connection and through the building). 


24 






3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


3.4 Who Should Collect the Samples and Where Do Samples Go for Analysis? - 
Collection and Analysis of Samples 

Deciding who will collect samples will be based, in part, on who will analyze the samples. Choosing an 
individual who is adequately trained to collect samples may help avoid sampling errors. Some state drinking 
water programs or public water suppliers may provide both services, although there is no federal requirement 
that they do so. Regardless of who collects the samples, you should employ a certified laboratory to conduct 
sample analyses. Contact your state drinking water program (Appendix D) or EPA’s Safe Drinking Water 
Hotline (Appendix B and C) for a list of certified laboratories in your area. Consider the following issues prior 
to making a selection: 

• Will the laboratory take samples for you or will they provide training and sample containers for 
collectors designated by you? (Testing activities can be useless if sample collectors do not follow 
proper sampling procedures.) 

• If it is determined that a laboratory or other consultant will take your samples, make sure they 
understand the sample protocol. This protocol is described in the next section. Make sure that 
Laboratories or consultants thoroughly understand this protocol and do not confuse it with the lead testing 
protocol used by public water suppliers. The two protocol are different. 

• What is the cost of the laboratory’s services? Costs will vary, depending upon the extent of the services 
to be provided (e.g., if only analyses are conducted or if other sendees such as sample collection are 
provided). You may want to contact several laboratories to compare prices and services, and you may 
wish to combine your sampling with another school to obtain a cheaper analysis rate. 

• What is the laboratory’s time frame for providing sample results? 

• Recordkeeping is a crucial activity. Appendix F contains a sample recordkeeping form and identifies the 
type of information you should consider recording. 

• Establish a written agreement or contract with the laboratory for all of the sendees to be provided. 


25 





3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Exhibit 3.2: Plumbing Configuration for a Single-Level Building 



26 






















































3Ts for Reducing Lead in Dnnking Water in Schools: Revised Technical Guidance 


Exhibit 3.3: Plumbing Configuration for a Multi-Level Building 



Note: Simplified header and 
lateral configurations 
are shown for clarity. 




Header 



- 


Water 

cooler 
^ 


A/ 



/ 


Riser 

Pipe 



Bubbler 





Laterajs^* 




-/ 




Service Connection 


School Building 





























































3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


4. Conducting Sampling 


4.1 General Sampling Procedures 

This section outlines the general procedures involved in collecting drinking water samples for lead testing, and 
the two-step sampling process for sampling at your school. Please note that the general two-step sampling 
process in this chapter contains recommendations for sampling that were created for typical plumbing 
configurations. If you believe that the recommendations do not fit your specific site conditions, you may 
wish to modify them as appropriate. See additional discussion in 4.4.3. EPA strongly recommends that all 
water outlets in all schools that provide water for drinking or cooking meet a standard of 20 parts per 
billion (ppb) lead or less. 


4.2 Collection Procedures 

(1) All water samples collected should be 250 milliliters (mL) in volume. School samples are smaller than 
the one liter sample collected by public water suppliers for compliance with the Lead and Copper 
Rule. A smaller sample is more effective at identifying the sources of lead at an outlet because a 
smaller sample represents a smaller section of plumbing. A smaller sample is also more representative 
of water per serving consumed by a child. A 250 mL sample from a faucet would not include 
portions of the plumbing behind the wall that the faucet is mounted on, for example, compared to a 
1000 mL (1 liter) sample, which would include a longer line of plumbing with its valves and tees and 
elbows and soldered joints. 

(2) Collect all water samples before the facility opens and before any water is used. Ideally, the water 
should sit in the pipes unused for at least 8 hours but not more than 18 hours before a sample is taken. 
However, water may be more than 18 hours old at some outlets that are infrequently used. If this is 
typical of normal use patterns, then these outlets should still be sampled. 

(3) Make sure that no water is withdrawn from the taps or fountains from which the samples are to be 
collected prior to their sampling. 

(4) Unless specifically directed to do so, do not collect samples in the morning after vacations, weekends, 
or holidays because the water will have remained stagnant for too long and would not represent the 
water used for drinking during most of the days of the week. 

(5) Assign a unique sample identification number to each sample collected - use your sampling plan 
schematic or numbering system. Record the identification number on the sample bottle and on your 
recordkeeping form (see Appendix F). On your recordkeeping form include information on: 

• Type of sample taken, e.g., initial, first follow-up, etc. 

• Date and time of collection. 

• Name of the sample collector. 

• Location of the sample site. 

• Name of the manufacturer that produced the outlet, and the outlet’s model number, if 
known. 

Consult the sample form in Appendix F for additional recordkeeping items. 


28 









3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


4.3 Laboratory Analysis and Handling of Sample Containers 

As discussed in the previous chapter, the certified drinking water lab that you select will either collect the 
samples for you or they will provide you with materials and instructions if you plan to collect your own 
samples. 

If you collect your own samples, follow the instructions provided by the laboratory for handling sample 
containers to ensure accurate results {also see Appendix G — Preservation of Samples and Sample Containers ). 
Make sure the containers are kept sealed between the time of their preparation by the lab and the collection of 
the sample. Be sure to carefully follow the laboratory’s instructions for preservation of the samples. Icing or 
refrigeration of the samples will likely be necessary. Most laboratories will provide shipping containers and ice 
packs if shipping is necessary. 


When the laboratory returns your test results, the concentrations of lead in your drinking water samples will be 
reported in metric form such as milligrams per liter (mg/L) or micrograms per liter (pg/L), or they will be reported as a 
concentration such as parts per million (ppm) or parts per billion (ppb), respectively. 

Milligrams per liter (mg/L) is essentially the same as parts per million (ppm). Micrograms per liter (pg/L) is essentially 
the same as parts per billion (ppb). 

Examples : 1 mg/L = 1000 pg/L = Ippm =1000ppb; 0.020 mg/L = 20 pg/L = 0.02ppm = 20ppb 


4.4 Overview of the Two-Step Sampling Process 

EPA recommends that a two-step sampling process be followed for identifying lead contamination. Lead in a 
water sample taken from an outlet can originate from the outlet fixture (the faucet, bubbler etc.), or plumbing 
upstream of the outlet fixture (pipe, joints, valves, fittings etc.). The two-step sampling process helps to 
identify the actual source(s) of lead. 

In Step 1, initial samples are collected to identify the location of outlets providing water with elevated lead 
levels. In Step 2, follow-up water samples are taken only from problem locations to determine the lead level 
of water that has been stagnant in upstream plumbing, but not in the outlet fixture. The results of initial and 
follow-up samples are then compared to determine the sources of lead contamination and to determine 
appropriate corrective measures. 

The protocol, which consists of an established sample size volume and water retention time, is designed to 
identify lead problems at outlets and upstream plumbing within school facilities. 

This section provides a brief definition and overview of the purpose of each of the two steps in EPA’s lead 
testing process. 

4.4.1 Step 1: Initial Sampling 

In Step 1, initial screening samples are taken from the service connection and the prioritized outlets in the 
facility. These initial samples determine: a) the lead content of water from your facility’s service connection 
and b) the lead content of water sitting in water outlets that are used for drinking or cooking within your 
building(s). The goal of Step 1 is to compare the lead level of water from your facility’s service connection to 
water that has remained stagnant in the outlet or fixture. 


29 








3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


To determine the lead content in water from your facility’s service connection, first contact your public water 
supplier to identify what lead levels you might expect. (Ifyou completed the plumbing profile questionnaire in 
Appendix I that is also discussed in Exhibit 3.1, you will already have this information.) Second, test water that 
is representative of your service connection and the mains in your public water system. Compare the results to 
determine what contribution your service connection is making to lead concentrations in your building (see 
Exhibit 4.3). Then, compare this finding to the results from outlets in the facility. For sampling instructions 
for initial samples from service connections, mains, and different types of water outlets, see Exhibits 4.3 
through 4.9. 

Before beginning sampling, you should repair any leaking outlets to ensure that you collect representative 
samples. 

4.4.2 Step 2: Follow-Up Sampling 

If initial test results reveal lead concentrations greater than 20 ppb in a 230 mL sample for a given outlet, 
follow-up testing described in Step 2 is recommended to determine if the lead contamination results are from 
the fixture or from interior plumbing. EPA has established this trigger for follow-up testing to ensure that the 
sources of lead contamination in drinking water outlets are identified. 

In Step 2, follow-up samples are collected and analyzed from outlets whose initial test results revealed lead 
concentrations greater than 20 ppb. The purpose of Step 2 is to pinpoint where (e.g., fixtures or interior 
plumbing) lead is getting into drinking water so that appropriate corrective measures can be taken. 

As with initial samples, follow-up samples are to be taken before a facility opens and before any water is used. 
Follow-up samples generally involve the collection of water from an outlet where the water has run for 30 
seconds. This sampling approach is designed to analyze the lead content in the water in the plumbing behind 
the wall. The sampler should induce a small (e.g., pencil-sized) steady flow of water from the outlet or other 
sample location. The sampler should be careful not to begin with a high rate of flow, and then reduce the 
flow just prior to sampling. Sudden changes in flow could stir up sediments or cause sloughing of pipe films 
that would not be characteristic of typical water use patterns. 

A comparison of initial and follow-up samples will help to assess where the lead may be getting into the 
drinking water. See Exhibits 4.3 through 4.8 for follow-up sampling instructions for various types of outlets. 

After follow-up sampling, additional samples from the interior plumbing within the building are also often 
necessary to further pinpoint the sources of lead contamination. See Exhibit 4.9 for instructions for additional 
sampling. 

After reviewing the plumbing profile questionnaire and background regarding what your answers to the profile 
could mean (Exhibit 3.1), you have learned that lead contamination may not occur uniformly throughout a 
building. You should have an idea of the type of water you are receiving. From this assessment, you will then 
have a better sense of how to organize your testing activities. When planning your strategy, it is important to 
note that large variations in lead concentrations may be found among individual outlets in a facility because of 

differences in flow rates and/or building materials. 


30 









3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


In general, you may find widespread presence of lead in your drinking water when: 

• Lead pipes are used throughout the facility. 

• The building’s plumbing is less than 5 years old and lead solder was illegally used (i.e., after the “lead- 
free requirements of the 1986 Safe Drinking Water Act Amendments took effect). This situation is 
rare. 

• The water is corrosive. 

• Sediment or scale in the plumbing and faucet screens contain lead. 

• Brass fittings, faucets, and valves were installed throughout the building less than five years ago (even 
though they may contain less than the “lead-free” requirements of the Safe Drinking Water Act). 

• The service connection (i.e., the pipe that carries water from the public water system main to the 
building) is made of lead. 

In general, you may find localized presence of lead if: 

• Some brass fittings, faucets, and valves have been installed in the last five years (even though they may 
meet the SDWA “lead-free” requirement). 

• Drinking water outlets are in line with brass flush valves, such as drinking water fountains near 
restroom supply piping. 

• Lead pipes are used in some locations. 

• The water is non-corrosive. 

• Lead solder joints were installed in short sections of pipe before 1986 or were illegally installed after 
1988 (i.e., after the lead-free requirements of the Safe Drinking Water Act took effect). 

• There are areas in the building’s plumbing with low flow or infrequent use. 

• Sediment in the plumbing and screens frequently contains lead. 

• Some water coolers or other outlets have components that are not lead-free, especially if the water is 
corrosive. 

After identifying potential problem areas in your facility through completion of a plumbing profile, the next 
step is to have the water tested. A sampling plan should be developed before testing begins. Key issues to 
consider in devising a sampling plan include the following: 

• Who will be in charge of the sampling effort? 

• Who will collect and analyze samples and maintain records? 

• Where will the samples be taken? 


31 






3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


4.4.3 Initial and Follow-Up Sampling Protocol 

The protocol for collecting initial and follow-up samples varies by type of drinking water outlet. The initial 
and follow-up testing protocol and the interpretation of test results is described in Exhibits 4.3 thorough 4.9 
for the following locations and type of outlets: 

• Service connections and water mains 

• Drinking water fountains (four types) 

• Bubblers or drinking water fountains (without central chillers): water is supplied to the 
bubbler or fountain directly from the buildings plumbing. 

• Bubblers or drinking water fountains (with central chillers): a central chiller unit cools water 
for a number of drinking water fountains or bubblers in the building. 

• Water coolers: devices are equipped with their own cooling and storage systems; water is 
supplied to the device from the building’s plumbing. 

• Bottled water dispensers: type of water fountain whose water is supplied from bottled water. 

Note: The Food and Drug Administration (FDA) regulates bottled water. EPA recommends 
testing the dispenser to ensure that the dispenser is not contributing lead to the water. 

• Ice making machines 

• Water faucets 

• Interior plumbing 

Please note that sampling ID codes have been 
indicated in the descriptions of the sampling 
protocol for each outlet type. These sampling ID 
codes have been included for illustrative purposes 
only. When you conduct testing in your facility, you 
should assign your unique numbers for every sample 
you collect. 

Following the instructions for the above water outlet 
locations are instructions for conducting sampling of 
the interior plumbing of buildings (Exhibit 4.9). 

Instructions are included for sampling laterals, loops 
and headers, and riser pipes. These types of samples 
are necessary if follow-up outlet samples show lead 
levels above 20 ppb. 

Exhibit 4.2 provides an overview of the sampling process in a flow chart format. 


TIP: Schools may wish to collect both initial and 
follow-up samples at the same time. This is more 
convenient and may save time and money if a 
contractor has been hired to collect the samples. 
However, using this approach creates a trade-off 
between convenience and confidence. The 
confidence in the sample results will decrease since 
flushing water through an outlet after taking the 
initial sample could compromise the flushed 
samples taken at subsequent outlets, depending 
upon the plumbing configuration. As succeeding 
outlets are flushed, the chances of compromising 
the remaining flushed samples would increase. 


32 




3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


As discussed in section 4.1, you may wish to modify sampling recommendations to suit your site conditions. 
For example, if you believe that flushing an outlet for 30 seconds prior to taking a follow-up sample is 
excessive, you may wish to calculate a more accurate time estimate. This could be done by: 

• Calculating the pipe volume in gallons between the outlet and the location in the plumbing that you 
want to sample. 

• Measuring the outlet flow in gallons per minute. 

• The length of time for flushing can be determined by dividing the pipe volume in gallons by the 
outlet flow in gallons per minute. 

Pipe volumes per foot of pipe length for various pipe sizes are shown in Exhibit 4.1 below. 


Exhibit 4.1: Pipe Volumes for Copper Pipe 


Nominal 

Pipe Diameter 
(inches) 

Approximate Capacity 
(gallons per foot of length) 

Type K Copper 
(soft) 

Type L Copper 
(rigid) 

3/8 

0.0066 

0.0075 

1/2 

0.0113 

0.0121 

3/4 

0.0226 

0.0251 

1 

0.0404 

0.0429 

1 1/4 

0.0632 

0.0653 

1 1/2 

0.0893 

0.0924 

2 

0.1566 

0.1607 

2 1/2 

0.2412 

0.2479 

3 

0.3448 

0.3538 


33 

















3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Exhibit 4.2: Sample Strategy Flowchart 



34 




































3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


4.4.4 Sampling for Other Parameters 

In addition to monitoring for lead, you may wish to monitor for other parameters that may provide an 
indication of problems in your plumbing. However, note that analysis costs will increase as the number of 
parameters increases. Some other parameters are listed in the following table: 


Contaminant 

Limit 

Concern 

Cadmium 

5 ppb 

A regulated toxic metal found in low levels in galvanized pipe. 

The maximum allowable level is 5 ppb. However, the presence of 
cadmium at any level indicates that corrosive conditions may exist 
in the plumbing. 

Color 

15 color 
units 

An aesthetic parameter that may indicate the presence of iron 
oxides. Iron oxides are often present in iron or steel pipe as a 
result of corrosive conditions. 

Copper 

1300 ppb 

A regulated toxic metal used to make copper piping. The 
presence of copper in water samples taken from copper piping is 
not unusual, but higher levels indicate that corrosive conditions 
may be a concern. 

Iron 

300 ppb 

An aesthetic parameter that is indicative of corrosive conditions at 
higher levels. See also color and turbidity. (Galvanized pipe is 
typically made of iron.) 

Turbidity 

1 turbidity 
unit 

A measurement of the clarity of water. Higher turbidity values 
may indicate the presence of iron oxides. Iron oxides are often 
present in iron or steel pipe as a result of corrosive conditions. 

Zinc 

3000 ppb 

An aesthetic parameter that is indicative of corrosive conditions at 
higher levels. Zinc is used in making galvanized piping products. 
The presence of zinc in water samples taken from galvanized 
piping is not unusual, but higher levels indicate that corrosive 
conditions may be a concern. 


35 













3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Exhibit 4.3: Service Connection Sampling 


Lead pipes are still used for service connections in some locations. Other materials used for service connections 
include copper, galvanized steel, plastic, and iron. Lead service connections can produce significant lead levels 
in your drinking water. 

To test water in your service connection, locate the tap closest to the service connection. This is especially 
important for larger facilities where more than one service connection is present. 


Sample Collection Procedures: 


School Building 



Targeted Locations of Water in Plumbing 
for Samples IS & 1M 


Sample IS (Service Connection) 

Take this sample before the facility opens. Note that this is not an initial first-draw sample. Open the cold 
water tap closest to the service connection. Let the water run, and feel the temperature of the water. 
Depending upon the temperature of your public water system’s water and the temperature of the room, you 
may feel the water temperature change as the water from the service connection enters the building. However, 
it is possible that the water in the service connection and the building are close to the same temperature. 
Therefore, you should collect the sample immediately after a temperature change is detected, or after 30 
seconds. Flushing removes the water that was in the facility’s interior plumbing and allows sampling of the 
water that was in the service connection. You may wish to calculate a more accurate flush time for your 
building by using the method described in section 4.4.3. 

Sample 1M (Water Main) 

This sample is representative of the water that is provided by the distribution main. Take the sample from the 
same location as sample IS. Let the water run, and feel the temperature of the water. If you can feel a change 
in water temperature, allow the water to run an additional 3 minutes after the temperature changes and then 
collect the sample. If you cannot feel a change in temperature, allow the water to run for 3 minutes and 30 
seconds. 


36 














3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


If possible, you should take this sample from a faucet rather than a drinking fountain because of the limited 
flow that is normally provided by a drinking fountain. Also, a change in temperature may be difficult to 
detect if the sample is taken from a water cooler (see the discussions for Samples IS and 1M below). 

Interpreting Test Results: 

• If the lead level of Sample IS (service connection) significantly exceeds 5 ppb (for example, 10 ppb) 
and is higher than in sample 1M, lead is contributed from the service connection. Check for the 
presence of a lead service connection by scratching it with a knife or key. (Lead test kits are available 
from water testing and laboratory supply companies and are relatively inexpensive.) Lead is soft and 
dull gray in appearance. When scratched, it will be shiny. In the absence of a lead service connection, 
lead goosenecks or other materials containing lead may be the source of the contamination. 

• If the lead level of Sample 1M (water main) significantly exceeds 5 ppb (for example, 10 ppb), lead in 
the water may be attributed to the source water, sediments in the main, or to lead in the distribution 
system such as from lead joints used in the installation or repair of cast iron pipes. 

• If the lead level of Samples IS and 1M are very low (close to 5 ppb), very little lead is being picked up 
from the service line or the distribution main. Usually, no significant amount of lead (above 5 ppb) 
comes from the public water system. 

For example scenarios of different water sample results, please see Appendix H. 


37 






3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Exhibit 4.4: Drinking Water Fountains: Bubblers 


Do not close the shut-off valves to the water fountains to prevent their use prior to sample collection. Minute 
amounts of scrapings from the valves will produce inaccurate results showing higher than actual lead levels in the 
water. Take all samples with the taps fully open. 


Sample Collection Procedures: 

• Initial Screening Sample 1A 

This sample is representative of the water that may be consumed at the 
beginning of the day or after infrequent use. It consists of water that 
has been in contact with the bubbler valve and fittings and the section 
of plumbing closest to the outlet of the unit. 

Take this sample before the facility opens and before any water is used. 
Collect the water immediately after opening the valve without allowing 
any water to run into the drain. Take follow-up samples from those 
bubblers where test results indicate lead levels over 20 ppb. 

• Follow-Up Sample 2A 

This sample is representative of the water that is in the plumbing 
upstream from the bubbler (from the bubbler back 
toward the service connection and the water main). 

Take this sample before the facility opens and 
before any water is used. Let the water from the 
fountain run for 30 seconds before collecting the 
sample. If several bubblers are served by a central 
chiller, samples should be taken from different 
bubblers on different days. 



One Style of Drinking 
Water Fountain 



Targeted Locations of Water in Plumbing 
for Samples 1A & 2A 

Note: All the samples are collected at the 
outlet. The sample numbers indicate 
what water is being targeted for testing. 


38 




















3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Interpreting Test Results: 

To determine the source of lead in the water, compare the 
test results of Samples 1A and 2A. 

• If the lead level in Sample 1A is higher than that in 
Sample 2A, a portion of lead in the drinking water is 
contributed from the bubbler. 

• If the lead level in Sample 2A is very low (close to 5 
ppb), very little lead is picked up from the plumbing 
upstream from the outlet. The majority or all of the 
lead in the water is contributed from the bubbler. 

• If the lead level in Sample 2A significantly exceeds 5 Fountains Connected to a Central Chiller 
ppb (for example, 10 ppb), lead in the drinking water 

is also contributed from the plumbing upstream from the bubbler. 

• If the lead level in Sample 2A exceeds 20 ppb, EPA recommends sampling from the header or loop 
supplying water to the lateral to locate the source of the contamination. (Sampling instructions for 
interior plumbing can be found in Exhibit 4.9.) 



For example scenarios of water sample results and possible solutions, see Appendix H. 


39 














3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Exhibit 4.5: Drinking Water Fountains: Water Coolers 

Do not close the valves to the water fountains to prevent their use prior to sample collection. Minute amounts of 
scrapings from the valves will produce inaccurate results showing higher than actual lead levels in the water. Take all 
samples with the taps fully open. 

Sample Collection Procedures: 

Two types of water coolers are used: the wall-mounted 
and the free-standing types. Water in these coolers is stored 
in a pipe coil or in a reservoir. Refrigerant coils in contact 
with either of these storage units cools the water. Sources 
of lead in the water may be the internal components of the 
cooler, including a lead-lined storage unit; the section of 
the pipe connecting the cooler to the lateral pipe; and/or 
the interior plumbing of the building. 

Prior to testing, check the make and model numbers of 
your water coolers and compare them to EPA’s listing of 
coolers that have lead parts or lead-lined tanks (see 
Appendix E for a summary of the water cooler issues and 
EPA's list of affected coolers). If you have a Halsey Taylor 
cooler that is on EPA’s list of coolers with lead-lined tanks, consult Halsey Taylor for information on their 
replacement/refund program and associated testing directions. Contact information is provided in Appendix 
E. 

Regardless of whether your water cooler appears on EPA’s listing, initial testing should be conducted. 

• Initial Screening Sample 1C 

This sample is representative of the water that may be consumed at the beginning of the day or after 
infrequent use. (In areas of infrequent use, the 
water may not have been used in more than 18 
hours. This is acceptable if this is representative 
of the normal water consumption pattern.) 

The sample consists of water that has been in 
contact with the interior plumbing, the valve 
and fittings, the storage unit, and the section of 
plumbing closest to the outlet of the unit. 

Take this sample before the facility opens and 
before any water is used. Collect the water 
immediately after opening the faucet without 
allowing water to waste. Take follow-up 
samples from water coolers whose test results 
indicate lead levels greater than 20 ppb. 

When conducting follow-up testing with water 
coolers you should be aware that some water 



Targeted Locations of Water in Plumbing 
for Samples 1C - 4C 

Note The valve shown upstream of the water cooler may be 
located inside the cooler. 



40 






























3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


coolers manufactured before 1988 may have storage tanks lined with materials containing lead. You 
should contact the manufacturer of any water cooler units you have purchased or are planning to 
purchase for written guarantees that the unit is lead-free. A list of makes and model numbers of coolers 
that contain lead has been prepared by EPA and is summarized in Appendix E. 

• Follow-Up Sample 2C 

This water sample is representative of the water that is in contact with the header or rising piping 
upstream of the cooler. Take this sample after the facility closes. Let the water from the fountain run 
for 15 minutes before collecting the sample. You must flush the cooler for 15 minutes to ensure that 
no stagnant water is left in the storage unit. 

• Follow-Up Sample 3C 

Take this sample before the facility opens and before any water is used. This sample must be taken the 
morning after you collect Follow-Up Sample 2C. Collect the water immediately after opening the 
faucet without allowing any water to waste. 

Because the water in the cooler was flushed the previous afternoon, this sample is representative of the 
water that was in contact with the cooler overnight, not in extended contact with the plumbing 
upstream. As such, it may differ from Initial Screening Sample 1C. 


41 




3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Interpreting Test Results: 


• IF 

Follow-up 

IS GREATER THAN 

Follow-up 


Sample 3C 


Sample 2C 


The water cooler may be contributing 
> lead. 


Follow-up 
Sample 3C 

IS GREATER THAN 

Follow-up 
Sample 2C 




Initial 

Sample 1C 

IS GREATER THAN 

Follow-up 
Sample 3C 


The upstream plumbing may also be 
^ contributing lead. 


• LE 

Follow-up 

IS CLOSE OR 

Follow-up 

Sample 2C 

EQUAL TO 

Sample 3C 


- > 

The water cooler is probably not 
contributing lead. 


• IE 

Follow-up 
Sample 1C 

IS GREATER THAN 

Follow-up 
Sample 3C 






Follow-up 

IS CLOSE OR 

Follow-up 


Sample 2C 

EQUAL TO 

Sample 3C 


The u<ater cooler and/or upstream 
^ tolumbina are orobablv contributing 

lead. 


• IE 

Follow-up Sample 
2C > 20 ppb, AND 

IS GREATER THAN 

OR EQUAL TO 

Initial Sample 1C & 
Follow-up Sample 

3C 


The source of the lead may be sediments 
contained in the cooler storage tank, 

^ screens, or the plumbing upstream from 
the cooler. 


THEN 


AND 


THEN 


THEN 


AND 


THEN 


THEN 


42 





























3Ts for Reducing Lead in Dnnking Water in Schools: Revised Technical Guidance 


Follow-Up Sample 4C 

To confirm whether the cooler is the source oflead, take Follow-Up Sample 4C. 

Turn off the valve leading to the cooler. Disconnect the cooler from the plumbing and look for a 
screen at the inlet. Remove the screen. If there is debris present, check for the presence oflead solder 
by sending a sample of the debris to the laboratory for analysis. 

Some coolers also have a screen installed at their outlet. Carefullv remove the bubbler outlet bv 
unscrewing it. Check for a screen and debris and have a sample of any debris analyzed. 

Some coolers are equipped with a drain valve at the bottom of the water reservoir. Water from the 
bottom of the water reservoir should be sampled and any debris analyzed. 

Collect Sample 4C from the disconnected plumbing outlet in the same manner as you collected 
Sample 1C. Compare the results from Sample 4C to the other sample results. 


Interpreting Additional Water Cooler Test Results: 


The lead is coming from debris in 
the cooler or in the screen. 


The lead is coming from debris in 
the cooler or in the screen. 


IF 



IS LESS THAN 5 ppb, 
THEN 


IF 



IS MUCH GREATER 
THAN 5 ppb. THEN 


• IF 


Follow-up 
Sample 4C 


IS MUCH GREATER 
THAN 5 ppb, AND LESS 
THAN 


Initial 
Sample 1C 


THEN 




The source of lead may be sediments contained in the cooler, screens, and/or the 
upstream plumbing. 


For example scenarios of water sample results and possible solutions, see Appendix H. 


43 
















3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Exhibit 4.6: Drinking Water Fountains: Bottled Water Dispensers 

Sample Collection Procedures: 

This testing will identify if lead is being contributed to the water from the dispenser. 

Notes: The Food and Drug Administration (FDA), regulates the interstate sale of bottled water and has 
established a 5 ppb standard for lead in bottled water. EPA recommends that you contact your distributor for 
written assurance that the bottled water does not exceed federal or state bottled water standards, and a copy of 
recent test results. 

• Initial Screening Sample ID 

This sample is representative of the water that may be consumed at the 
beginning of the day or after infrequent use. It consists of water that has 
been in contact with the dispenser valve and fittings incorporated in the 
outlet of the unit. 

Take this sample before the facility opens and before any water is used. 

Collect the water immediately after opening the faucet without allowing 
any water to waste. Take follow-up samples from those bottled water 
dispensers where test results indicate lead levels over 20 ppb. 

• Follow-Up Sample 2D 

Collect this sample directly from the bottle that supplies the water to the 
unit. This will enable you to determine the source of lead in the water. See 
the Note below for an alternative to follow-up sampling. 

reting Test Results: 

If the sample contains lead, contact the water supplier and/or 
the manufacturer of the dispenser to ask for their 
recommendations. 

If the lead level in Sample 1D is higher than that in Sample 
2D, lead may be coming from the dispenser unit. 

If the lead level in Sample 2D is identical or close to that in 
Sample ID, the source of lead is the bottled water. 

Note: Many dispensers have a hot and cold tap. Water from both taps 
is meant to be directly consumed, therefore, both taps should be sampled. 

However, you may wish to sample the hot water tap on a separate day. 

For example scenarios of water sample results and possible solutions, 
see Appendix H. 



Bottled Water Dispenser 

— 


2D 




$◄10 


Targeted Locations of Water in Plumbing 
for Samples 1D & 2D 



Bottled Water 


Dispenser 


44 
























3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Exhibit 4.7: Ice Making Machines 

Sample Collection Procedures: 

• Initial Screening Sample IE 

Fill a suitable container (250 mL or larger, 
wide-mouthed bottle or other container) 
provided by the laboratory at least three- 
quarters full of ice. Do not touch the ice 
with your hands. Use the non-metal scoop 
or disposable plastic gloves provided by the 
laboratory to place the ice in the container. 

If the lead level in Sample IE exceeds 20 
ppb, collect a follow-up sample to determine 
if the source of the lead is the plumbing or 
the ice making machine itself. 

• Follow-Up Sample 2E 

Disconnect the ice maker from the 
plumbing and look for a screen at the inlet. Remove the screen. If debris is present, forward a sample 
of the debris to the laboratory for analysis and clean out the remaining debris. The laboratory will 
determine whether lead solder is present. Clean the screen routinely to avoid accumulations of debris. 

Collect the sample from the disconnected plumbing as close to the ice maker as possible. Fill the 
sample container with 250 mL of water. If no tap is available, contact the ice machine manufacturer 
for recommendations that will minimize disruption of existing plumbing. Adding taps or valves 
could add new sources of lead to the plumbing, even if the new devices are lead-free and meet NSF 
Standard 61, section 8. If a sample tap or valve is available, collect the sample immediately after 
opening the tap or valve. 

Interpreting Test Results: 

• If the lead level in Sample 2E is close to 5 ppb, the source of the lead in the ice is the ice maker. 

• If the lead level in Sample 2E significantly exceeds 5 ppb (for example, 10 ppb), lead is also 
contributed from the plumbing upstream from the ice maker. 

• If the lead level in Sample 2E exceeds 20 ppb, EPA recommends sampling from the distribution 
system supplying water to the ice maker. Refer to Exhibit 4.9 on Sampling Interior Plumbing for 
instructions. 

For example scenarios of water sample results, please see Appendix H. 



45 














3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Exhibit 4.8: Water Faucets (Taps) 


Sample Collection Procedures: 

• Initial Screening Sample IF 

This sample is representative of the water that may 
be consumed at the beginning of the day or after 
infrequent use. It consists of water that has been in 
contact with the Fixture and the plumbing 
connecting the faucet to the lateral pipes. 

Take this sample before the facility opens and before 
any water is used. If the tap has an aerator (screen), 
remove, clean, and replace it prior to collecting the 
sample. Using the cold water tap, collect the water 
immediately after opening the faucet without 
allowing any water to go to waste. Follow-up 
samples should be taken from those water faucets 
where initial screening test results indicate lead levels 
over 20 ppb. 

• Follow-Up Sample 2F 

This sample is representative of the water that is in 
the plumbing upstream from the faucet. Take this 
sample before school opens and before any water is 
used. Let the water from the faucet run for 30 
seconds before collecting the sample. 

Interpreting Test Results: 

• If the lead level in Sample 1F is higher than that in Sample 2F, the source of lead is the water faucet 
and/or the plumbing upstream from the faucet. 

• If the lead level in Sample 2F is very low, close to 3 ppb, very little lead is coming from the plumbing 
upstream from the faucet. The majority or all of the lead in the water is from the faucet and/or the 
plumbing connecting the faucet to the lateral. 

• If the lead level in Sample 2F significantly exceeds 5 ppb (for example, 10 ppb), lead may be 
contributed from the plumbing upstream from the faucet. 

For example scenarios of water sample results and possible solutions, see Appendix H. 



Targeted Locations of Water in Plumbing 
for Samples 1F & 2F. 


46 


















3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Exhibit 4.9: Sampling Interior Plumbing 

In general, if lead levels exceed 20 ppb in follow-up samples taken from drinking water outlets, additional 
samples from upstream sample sites in the interior plumbing should be collected. EPA recommends that 
water samples from each lateral, header and riser (where applicable) be collected because use patterns may vary 
among locations within a building. The configuration of interior plumbing will vary depending on the layout 
of a given building. Construction materials may also vary, especially in larger buildings where additions and 
repairs have been made to the original structure. See Exhibits 4.10 and 4.11 for simplified diagrams of the 
interior plumbing in single-level and multi-level buildings. 

Sampling should proceed systematically upstream from follow-up sample sites that exceed 20 ppb. ( However ; 
you do not have to sample at upstream sites where follow-up samples have already been taken.) The goal of this 
sampling effort is to isolate those sections of the interior plumbing that contribute lead to the water. This is 
achieved by comparing the results of interior plumbing samples with each other, and with the results of 
previously collected follow-up samples. 

Developing procedures from upstream sampling from laterals, headers and risers can be difficult because of the 
wide variation in plumbing configurations among facilities. As discussed in 4.4.3, the sampling procedures in 
this manual were developed for typical configurations that may not be similar to your facility. You may wish 
to either develop your own sampling procedures using the guidance provided in 4.4.3, or retain a consultant 
for guidance in this process. 

Laterals 

A lateral is a plumbing branch between a fixture or group of fixtures (e.g., taps, water fountains, etc.) and a 
header. 

Sample Collection Procedures: 

• Sample 1G (lateral) 

Open the outlet that has been designated as the sample site for the lateral pipe. Let the water run for 
30 seconds before collecting the sample. Collect a 250 mL sample. The purpose of flushing the water 
is to clear the plumbing between the sample site and the lateral pipe. This action will ensure collection 
of a representative sample. 

Note: Sample 1G corresponds to follow-up samples taken from other outlets such as 2A, 2E and 2F. Compare the 
results of these samples from outlets upstream and downstream of Sample 1G for additional information on the 
source of the lead within the interior plumbing. (As noted above, you do not have to take sample 1G at sites 
where follow-up samples have already been taken. The previous results are adequate.) 


47 






3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Interpreting Test Results: 


• IF 


Follow-up 
Sample 1G 


IS GREATER THAN 20 ppb 


THEN 


Collect additional samples from the plumbing upstream where samples have 
note been previously taken; i.e., from the header that feeds the lateral, the riser 
pipe (if applicable), or the service connection. 


Note: High lead levels may be caused by recent repairs or by sediment in the 
plumbing. Sediment should be sent to a laboratory for analysis. 


• IF 


Follow-up 

IS CLOSE OR 

Initial results from a 

Sample 1G 

EQUAL TO 

downstream outlet 


THEN 


The lead is contributed from the lateral andJor from interior plumbing 
upstream from the lateral. Possible sources include the lateral, header, riser 
pipe, or service connection. 


• IF 


Follow-up 
Sample 1G 


IS CLOSE OR EQUAL TO 5 ppb THEN 


The portion of the lateral upstream from Sample Site 1G and the interior 
plumbing supplying water to the lateral are probably not contributing lead. 
The source is downstream from Sample Site 1G. 


• IF 


Follow-up 
Sample 1G 


IS APPROXIMATELY 10 ppb 
OR GREATER 
AND IS LESS THAN 


Initial results from a 
downstream outlet 


THEN 


> 


A portion of the lead is contributed from the plumbing downstream from 
Sample Site 1G. 


Headers 

A header is the main water supply pipe on a given floor of a building. A header supplies water to laterals. In 
smaller buildings, a header may be very short and/or have a relatively small diameter. 

Sample Collection Procedures: 

• Sample 1H (header) 

Locate the sampling point furthest from the service connection or riser pipe (see discussion of riser 
pipes on the next page) on the floor. You should try to take this sample from a faucet to provide 
adequate flushing through the tap. Open the faucet and let it run for 30 seconds before collecting this 
sample. Fill the sample container with 230 mL of water. The purpose of flushing the water is to clear 
the faucet and plumbing between the sample site and the header pipe. 


48 



























3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Interpreting Test Results: 


• IF 


Follow-up 
Sample 1 H 


IS GREATER THAN 20 PP h 


THEN 


Collect additional samples from the plumbing upstream that supplies water to 
the header (if not already done); i. e., the riser pipe (if applicable), or the service 
connection. 


Note: High lead levels rruiy be caused by recent repairs or by sediment in the 
plumbing. Sediment should be sent to a biboratoiy for analysis. 


• IF 


Follow-up 

IS CLOSE OR 

Initial results from a 

Sample 1H 

EQUAL TO 

downstream outlet 


FHEN 


The lead is contributed from the header and/orfrom interior plumbing 
upstream from the header. Possible sources include the header, riser pipe, or 
service connection. 


• IF 


Follow-up 
Sample 1 H 


IS CLOSE OR EQUAL TO 5 ppb 


THEN 


The portion of the header upstream from Sample Site 1H and the interior 
plumbing supplying water to the header are probably not contributing lead. 
The source is downstream from Sample Site 1H. 


IF 



IS APPROXIMATELY 10 PP b 
OR GREATER 
AND IS LESS THAN 


Initial results from a 
downstream outlet 


THEN 


A portion of the lead is contributed from the plumbing downstream from 
Sample Site 1H. 


49 






















3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Riser Pipes 

A riser is the vertical pipe that carries water from one floor to another. 

Sample Collection Procedures: 

• Sample 1J 

Open the tap closest to the riser pipe. Let the water run for 30 seconds before collecting the sample. 
Fill the sample container with 250 mL of water. The purpose of flushing is to clear the faucet and 
plumbing between the sample site and the riser pipe. 

Interpreting Test Results: 


• IF 


Follow-up 
Sample 1J 


IS GREATER THAN 


20 ppb, I HEN 


Collect additional samples from the plumbing upstream that supplies water to 
the riser (if not already done); i. e ., a riser from another floor, or the service 
connection. 


Note: High lead levels may he caused by recent repairs. 


• IF 


Follow-up 

IS CLOSE OR 

Initial results from a 

Sample 1) 

EQUAL TO 

downstream outlet 


THEN 


The lead is contributed from the riser and/or from interior plumbing upstream 
f ont the sample site. Possible sources include the riser pipes on other floors or 
the service connection. 


• IF 


Follow-up IS CLOSE OR 

Sample 1J EQUAL TO 


5 ppb THEN 


The portion of the riser upstream from Sample Site 1] and the service 
connection are probably not contributing lead. The source is downstream from 
Sample Site 1J. 


• IF 

Follow-up 

IS APPROXIMATELY 10 ppb 
OR GREATER AND IS LESS 

Initial results from a 


Sample 1J 

THAN 

downstream outlet 


THEN 


A portion of the lead is contributed from the plumbing downstream from 
Sample Site 1J. 


For example scenarios of water sample results and possible solutions, see Appendix H. 


50 

























3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Sample Collection Procedures - Central Chiller Unit: 

• Follow-Up Sample IK 

This sample is representative of water that has 
been in contact with the plumbing supplying 
water to the chiller. Take this sample before the 
facility opens and before any water is used. Take 
the sample from a tap or valve as close to the inlet 
of the chiller as possible. If no tap is available, 
contact the chiller manufacturer for 
recommendations that will minimize disruption 
of existing plumbing. Adding taps or valves could 
add new sources of lead to the plumbing, even if 
the new devices are lead-free and meet NSF 
Standard 61. If a sample tap or valve is available, 
collect the sample immediately after opening the 
tap or valve, without allowing any water to waste. 

• Follow-Up Sample 2K 
This water sample consists of water that has been in contact with the chiller unit and the plumbing 
upstream which supplies water to the chiller. Often, water supplied to the bubblers is recirculated to 
the chiller unit. In this instance, Sample 2K consists of a mixture of water from the water supply and 
any water that may be recirculated from the plumbing supplying water to the bubblers. 

Take the sample from a tap or valve as close to the outlet of the chiller as possible. If no tap is 
available, contact the chiller manufacturer for recommendations that will minimize disruption of 
existing plumbing. Adding taps or valves could add new sources of lead to the plumbing, even if the 
new devices are lead-free and meet NSF Standard 61. If a sample tap or valve is available, collect the 
sample immediately after opening the tap or valve. 

Interpreting Test Results - Central Chiller Unit: 

Note: You will need the results from samples collected at the bubblers per instructions in exhibit 4.4. 

• If the lead level in Sample 2A is higher than that in Sample 2K, lead is contributed from the plumbing 
supplying the water from the chiller to the bubbler. 

• If the lead level in Sample 2K is higher than in Sample IK, a portion of the lead may be coming from 
the chiller. Note: Sludge and sediments containing high levels of lead may accumulate in chiller 
tanks. If the test results indicate that lead is contributed from the chiller unit, check for the presence 
of debris and sludge. Remove any of these materials from the chiller, flush the chiller unit, and 
resample the water. 

• If the lead level in Sample IK exceeds 20 ppb, EPA recommends additional sampling from the 
distribution system supplying water to the chiller to locate the source of contamination. 

• If the lead level in Sample IK is very low (close to 5 ppb), very little lead is picked up from the 
plumbing upstream from the chiller. The majority or all of the lead in the water may be attributed to 
the chiller and the plumbing downstream from the chiller. 

For example scenarios of water sample results and possible solutions, see Appendix H. 

51 



Targeted Locations of Water in Plumbing 
for Samples IK & 2K 




















3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Exhibit 4.10: Sample Sites for a Single-Level Building 


Morning first-draw samples from coolers, 

1 faucets, bubblers, etc. (Initial Screening 
Samples 1A, 1C, ID, IE, IF.) 

Samples from lateral after 30-second 

2 flush from designated outlets. (Follow-up 
Samples 2A, 2E, 2F, 1G.) 

~ Samples from coolers after 15-minute 
flush. (Follow-up Sample 2C.) 

^ Samples from coolers morning first- 
draw. (Follow-up Sample 3C.) 


Lateral 


Note: Simplified header and lateral 
configurations are shown for 
clarity. 


Morning first-draw from coolers at disconnected 
plumbing outlet. (Follow-up Sample 4C.) 

Sample from header pipe taken from faucet 
farthest from service line. (Sample 1H.) 

Sample from service line and distribution main taken 
from faucet closest to service line. (Samples 1M, IS.) 

Header 



Lateral 



5 

Cooler r 

Z5 

3 


Faucet 


Water Main 


Service Connection 


Note: all of these samples should not be collected on the same day 


Lateral 



6 


52 









































3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Exhibit 4.11: 


Sample Sites for a Multi-Level Building 


© 

© 

© 

© 


Morning first-draw samples from coolers, faucets, 
bubblers, etc. (Initial Screening Samples 1A, 1C, 
ID, IE, IF.) 

Samples from laterals after 30-second flush from 
designated outlets. (Follow-up Samples 2A, 2E, 
2F, 1G.) 

Sample from header taken from faucet farthest from 
riser pipe. (Sample 1H.) 

Sample from riser pipe taken from faucet closest to 
riser pipe. (Sample 1J.) 


© Samples from service line and distribution main 
taken from tap closest to service connection. 


© 


Note: Simplified header and 
lateral configurations 
are shown for clarity. 


Water Main 



(Sample 1H.) 

Sample from inlet to chiller unit. (Follow¬ 
up sample IK.) 

Sample from outlet of chiller unit. 
(Follow-up sample 2K.) 


Service Connection School Building 

Note: all of these samples should not be collected on the same day. 









































































3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


5. Remedies 


Solutions to lead problems typically need to be made on an interim (short-term) and on a permanent basis. 
Interim measures can be taken while you wait for your test results or until a permanent solution has been put 
in place. In addition, there are routine measures that should be taken. You should work closely with 
maintenance staff and any plumbers who may make repairs. Make sure that users are familiar with the use ol 
new fixtures you install. 

Outlined below are various routine, interim and permanent remedies. To aid you in the process of selecting 
remedies, a case study has been included as Exhibit 5.3. 


5.1 Routine Control Measures 

Below are examples of routine activities that should be conducted to prevent exposure to elevated levels of 
lead: 

• Clean debris from all accessible screens frequently. If you discovered sediments in faucet screens, have 
the sediments tested for lead and continue to clean your screens frequently, even if the analysis finds no 
lead. 

• Use only cold water for food and beverage preparation. Hot water will dissolve lead more quickly 
than cold water and is likely to contain increased lead levels. If hot water is needed, it should be taken 
from the cold water tap and heated on a stove or in a microwave oven. 

• Instruct the users (students and staff) to run the water before drinking or staff could run the water 
before students arrive, so they are drinking water that has not been in contact with the faucet interior 
since faucets are often a major source of lead in drinking water. 

• Placard bathroom sinks with notices that water should not be consumed. You should use pictures if 
there are small children using bathrooms. 


5.2 Interim (Short-Term) Control Measures 

Some examples of interim control measures include: 

(1) “Flush” the piping system in your building. “Flushing” involves opening suspect taps every morning 
before the facility opens and letting the water run to remove water that has been standing in the 
interior pipes and/or the outlets. The flushing time varies by the type of outlet being cleared. The 
degree to which flushing helps reduce lead levels can also vary depending upon the age and condition 
of the plumbing and the corrosiveness of the water. Flushing instructions are presented in Exhibit 5.1. 


54 












3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Exhibit 5.1: Flushing Directions by Outlet Type 


Remember that each drinking water outlet should be flushed individually; flushing a toilet will not flush your water 
fountains. All flushing should be recorded in a log submitted daily to the office, or person, in charge of this program. 

• Locate the faucet furthest away from the service line on each wing and floor of the building, open the faucets 
wide, and let the water run for 10 minutes. For best results, calculate the volume of the plumbing and the flow 
rate at the tap and adjust the flushing time accordingly. This 10-minute time frame is considered adequate for 
most buildings. 

• Open valves at all drinking water fountains without refrigeration units and let the water run for roughly 30 
seconds to one minute, or until cold. 

• Let the water run on all refrigerated water fountains for 15 minutes. Because of the long time period required, 
routinely flushing refrigerated fountains may not be feasible. It may therefore be necessary, and more 
economical, to replace these outlets with lead-free, NSF-approved devices. 

• Open all kitchen faucets (and other faucets where water will be used for drinking and/or cooking) and let the 
water run for 30 seconds to one minute, or until cold. 


Advantages: 

• Quickest and easiest solution to high lead levels, especially when contamination is localized in a small 
area or in a small building. 

• Does not require installation or maintenance of water treatment equipment. 

• Does not require complex instructions. 

Disadvantages: 

• The most obvious disadvantage to flushing is the potential waste of water involved in the flushing 
procedures. To minimize this disadvantage, consider the following: 

► Flush pipes only after weekends or vacations when lead levels may be highest (use only if lead 
levels do not exceed 20 ppb on a daily basis). 

► Thoroughly flush several designated drinking water outlets daily while taking all others 
temporarily out of service. 

► Use bottled water. 

► Collect water being flushed and use for non-consumptive purposes. 

• Another obvious disadvantage to flushing is the amount of time and staff needed to perform the task. 

• Flushing is not recommended as a practical remedy for water coolers. 

HINT: Be careful not to flush too many taps at once. This could dislodge sediments that might create further 
lead problems, or it could reduce pressure in the system below safe levels. If the flow from outlets is reduced 
noticeably during flushing, you have probably turned on too many taps at once. 


55 




3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


(2) Provide bottled water. This can be an expensive alternative but might be warranted if you expect or 
are aware of widespread contamination and flushing is not an option. If you use bottled water, be 
aware that it is not regulated by EPA but rather by the Food and Drug Administration (FDA). Your 
state may also regulate bottled water, and, in some instances, these standards may be more stringent 
than the federal requirements. EPA recommends that you require a written statement from the 
bottled water distributor guaranteeing that the bottled water meets FDA and state standards. 

(3) Shut off problem outlets. If initial sample results from an outlet exceed 20 ppb, the outlet can be 
shut off or disconnected until the problem is resolved. If the outlet had been frequently used, bottled 
water could be provided as a temporary replacement as suggested in item 2 above. 


5.3 Permanent Remedies 

You can take a number of actions to permanently reduce or eliminate the sources of lead that originate in your 
building’s plumbing. Some of these actions may allow the elimination or reduction of routine flushing or 
other interim measures. After obtaining an understanding of your water supply and the lead conditions in 
your facility (as a result of testing), you should examine the permanent treatment options and select those 
most appropriate to your situation. Obviously, your decision will be based on such factors as cost, likelihood 
of success, availability of water, and staffing requirements. 


( 1 ) 


Replacement. If the sources of lead contamination are 
localized and limited to a few outlets, replacing these 
outlets or upstream components may be the most 
practical solution. EPA worked with the plumbing 
industry and NSF International to develop an industry 
standard that is designed to minimize the amounts of 
lead being leached from these products. This standard is 
NSF Standard 61 (Sections 4, 8 and 9). Before you 
purchase any brass plumbing products, request 
information regarding compliance with this standard. 

NSF Standard 61, Section 4 covers pipes, fittings and 
small drinking water storage devices having domestic or 
residential applications, including the products or water 
contact materials of pipes, fittings, tubing, hoses, well casing, drop pipes and screens, etc. 


Tip: If multiple components (for 
example, bubbler valves) are in need of 
replacement, you may wish to purchase 
only one or two initially. You could 
then take follow-up water samples after 
installing the new component(s) to see 
if that particular product leaches 
unacceptable levels of lead. If follow¬ 
up testing is satisfactory, you could be 
reasonably certain that the product will 
perform well at other locations in your 
facility. 


NSF Standard 61, Section 8 covers inline mechanical devices that are used to measure or control the 
flow of water. Inline devices used to measure or control the flow of water in a building include water 
meters, building valves, check valves, meter stops, valves and fittings, backflow preventers, etc. An 
inline device is any device installed on a service line or building distribution system downstream of the 
water main and before endpoint devices. 


NSF Standard 61, Section 9 c overs endpoint devices. The devices include kitchen and bar faucets, 
lavatory faucets, water dispensers, drinking fountains, water coolers, glass fillers, residential refrigerator 
ice makers, supply stops, and endpoint control valves. Under the Lead Ban, these devices must meet 
the requirements of this standard. Be sure to check for compliance with NSF Standard 61, Section 9 
before purchasing or installing an endpoint device. 


56 









3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


(2) Lead levels can be reduced at the tap. Reverse osmosis units are commercially available and can be 
effective in removing lead. Since these devices also tend to make the water corrosive, they should only 
be used when placed at water outlets. Such devices are termed point-of-use (POU) devices. POU 
devices can be used to treat faucets or taps, but would not be used on drinking water fountains. There 
are a number of POU cartridge filter units on the market that effectively remove lead. 

POU devices can be either purchased or leased. They can be relatively inexpensive ($65 to $250) or 
expensive (ranging from $250 to $500), their effectiveness varies, and they may be vulnerable to 
vandalism. They also require a maintenance program for regular upkeep to ensure effectiveness. 
Cartridge filter units need to be replaced periodically to remain effective. NSF International, an 
independent, third-party certification organization, has a testing program to evaluate the performance 
of POU devices for lead removal (NSF Standard 53). Before purchasing any device, ask the 
manufacturer for proof of NSF approval and the Performance Data Sheet, or check by visiting the 
NSF Web site at http://www.nsf.org/business/search_listings/index/asp. 

(3) Check grounding wires. Electrical current may accelerate the corrosion of lead in piping materials. 
Existing wires already grounded to the water pipes can possibly be removed by a qualified electrician, 
and replaced by an alternative grounding system. If your local or state building codes allow, consider 
finding an alternative grounding system and have a qualified electrician make the change. Be aware 
that the removal of grounding from water pipes may create a shock hazard unless an acceptable, 
alternative ground is provided. 

(4) Lead pipe replacement. Lead pipes within the school and those portions of the lead service lines 
under the water supplier’s jurisdiction can be replaced. Contact your public water supplier regarding 
their jurisdiction. However, your facility may be responsible for replacing a portion of a lead sevice 
line that is under its own administrative jurisdiction, rather than under the jurisdiction of the water 
supplier. 

(5) Reconfigure plumbing. In some facilities, the plumbing system might be modified so that water 
supplied for drinking or cooking is redirected to bypass sources of lead contamination. Before 
undertaking such an alternative, be certain of the sources of lead contamination. Follow-up testing 
would also be necessary, as with the other remedies, to ensure that the efforts result in reduced lead 
levels at the tap. 

(6) Manual flushing. Flushing individual problem outlets or all outlets may also represent a permanent, 
albeit ongoing, solution. There are advantages and disadvantages to flushing. Flushing is often the 
quickest and easiest solution to high lead levels, especially when contamination is localized in a small 
area or in a small building. See the Interim Remedies section above for a discussion of the advantages! 
disadvantages of this remedy in addition to outlet flushing instructions. You should review this 
information before deciding whether flushing is appropriate as a permanent remedy in your facility. 

(7) Automatic flushing. Time-operated solenoid valves can be installed and set to automatically flush the 
main pipes (headers) of the system. It is important to note that solenoid valves are not practical for 
flushing water coolers. They would have to be flushed manually by staff. See the Interim Remedies 
section above for flushing instructions for waterfountains. 

(8) Bottled water. If other treatment fails or is impractical, bottled water can be purchased for 
consumption by the building community. As noted under the interim remedies section above, make 
sure that the bottled water you select meets federal and/or state standards for lead and other drinking 


57 






3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


water contaminants. EPA recommends that you require a written statement from the bottled water 
distributor guaranteeing that the lead levels in the water do not exceed 5 ppb. 

(9) Use lead-free materials. Make sure that any plumber who does repair or replacement work on the 
facility’s plumbing system uses only “lead-free” solders and other materials. The 1986 Safe Drinking 
Water Act Amendments require that only “lead-free” materials be used in new plumbing and 
plumbing repairs. Make sure all plumbers and other workers adhere to these requirements. These 
actions will ensure that new lead is not introduced into the facility’s plumbing system. Report any 
violations of the “lead-free” requirements to your local plumbing inspector, the state drinking water 
program or EPA (see Appendix D for a directory of state programs). 

(10) Shut off problem outlets. If initial sample results from an outlet exceed 20 ppb, the outlet can be 
shut off or disconnected permanently. If the outlet had not been used regularly, this may be a viable 
option. However, if the outlet had been frequently used, this is probably not a practical solution. 

Three flow charts (Exhibits 5.2a through 5.2c) illustrating a basic remediation process are presented below. 
Please note that these flow charts provide a basic process for developing permanent solutions to lead problems. 
Interim measures are therefore not specifically addressed on the charts. Also, for simplicity, not all of the 
possible permanent remedies listed in the above discussion are shown on the charts. However, these options 
provide additional flexibility and should be considered when using the flow charts. For example, a school 
might decide to provide a point-of-use reverse osmosis treatment unit at a kitchen sink tap in lieu of replacing 
high lead plumbing because a treatment unit would provide better overall water quality for cooking and it 
would remove lead from the water. 


58 










3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Exhibit 5.2a: Remediation Flow Chart (part 1) 



1 Point-of-use treatment devices or routine flushing measures may serve as 
alternatives to outlet replacement (see Section 5.3). Continue on with the flow chart. 









































3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Exhibit 5.2b: Remediation Flow Chart (part 2) 



1 Point-of-use treatment devices or routine flushing measures may serve as alternatives 
to outlet replacement (see Section 5.3). Continue on with the flow chart. 

2 Procedures include follow-up sampling and development of a plumbing profile (see Sections 3.1 and 4.4). 








































3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Exhibit 5.2c: Remediation Flow Chart (part 3) 



2 Procedures include follow-up sampling and development of a plumbing profile (see Sections 3.1 and 4.4). 


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3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Exhibit 5.3: Case Study 1 

This case study illustrates how one large school district addressed a long-standing lead problem. A variety of 
solutions were used to address lead problems at 50 schools in the district. 

Background 

Schools were sampled in 1991 and 1992 in response to the Lead Contamination Control Act. Drinking 
fountains with lead levels over 20 ppb were replaced. However, subsequent testing showed that levels at some 
outlets continued to be above 20 ppb. Internal recommendations to replace plumbing at four schools were 
not implemented due to many complex factors. A flushing program was implemented, but was not 
consistently applied. 

In 2003, a concerned parent conducted testing at one school because of iron staining problems. The testing 
showed that there were also lead problems at the school. Recognizing that the problem was likely widespread, 
the district put all schools over 7 years old on bottled water and sent a letter of notification to every parent. 

A consultant was hired to create a comprehensive testing program for almost 100 schools. A working group 
consisting of the schools local public water supplier, the county and state health departments, and 
toxicologists was formed to develop a comprehensive approach. 

A comprehensive water quality policy was adopted that includes standards for lead and 5 other contaminants. 
The standard for lead (10 ppb) is more stringent than EPA’s recommended Action Level for schools and 
public buildings. The policy includes procedures for short-term and long-term testing, and for remediation. 

Testing 

In cooperation with the working group, the district’s consultant developed plumbing profiles and a testing 
program, and the district began comprehensive lead testing in 2004 at 2400 sample locations. All drinking 
water fountains and cold water taps in classrooms, nurse’s offices, and kitchens were sampled. Other locations 
were sampled if they were deemed to be a potential health risk because of possible human consumption. Lead 
levels over 20 ppb were found at 25% of the locations. One location was 1600 ppb. Fifty schools were 
found to have at least one outlet with a problem. The water supplied by the local public water system was 
found to have typically less than 1 ppb lead and was ruled out as a source of lead. 


Testing also showed that flushing of the outlets for 30 seconds reduced the lead levels to below 20 ppb at all 
but 3% of the locations. Additionally, cadmium was found at 3% of the sample locations, and coliform- 
positive samples were found at 6 schools. 

Remediation 

The district adopted a policy for mitigation that included a target level of 10 ppb for lead. Additionally, the 
EPA public water supply standards for cadmium, copper, iron and coliform bacteria were adopted. (The EPA 
standard for iron is a secondary standard, which means that the standard is primarily an aesthetic standard 
rather than health-based. Under federal law, public water supplies are not required to comply with secondary 
standards.) Compliance with the district’s adopted standards will be maintained through fixture replacement, 
filtration, replacement/rehabilitation of lines, or disabling of outlets. 


62 


Fountains and other outlets that produce lead analysis results higher than 10 ppb will be fixed or disabled. 
Fixtures with confirmed levels of iron over 0.5 ppm will be fixed or removed from service. If more than one- 





3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


half of the drinking water sources in a school or in a wing of a school exceed 0.3 ppm iron, further 
remediation for iron will be addressed by the district. 

The plumbing in the four schools originally targeted for replacement was fixed in the Summer of 2004. 
Eventually, the plumbing in all schools will be replaced or rehabilitated so the adopted water quality standards 
can be maintained. The approach used will range from complete piping replacement in just a few schools (no 
more than 7 total, including the 4 already done), to partial piping replacement in a number of schools 
(perhaps 13 total), to fixture replacement in many schools. 

Bottled water is provided at all schools or locations within a school which have lead problems until problems 
are addressed. Drinking water is easily available to all students and all staff throughout the school day. After 
compliance with the adopted water quality standards is achieved, periodic testing will continue every three 
years until it is demonstrated that less frequent testing is necessary. 

Public Education 

The district understands the importance of informing parents, students, and staff of water quality policy and 
testing results. 

Additionally, the district adopted the following steps: 

• Qualified experts were retained to obtain the best advice. 

• A public oversight committee was created to ensure awareness and involvement of the public. 

• Community meetings are held as necessary to keep the public updated. 

• School board briefing sessions related to lead are open to the public. 

• A comprehensive Web site has been developed that includes health effects information, FAQs, contact 
information, and testing results for each school in the district. 

Lessons Learned 

The district had attempted to address the Lead Contamination Control Act in 1991 and 1992 through 
testing, replacement of drinking water fountains and flushing. Fountains that tested over 20 ppb were 
replaced until subsequent testing revealed that problems with lead persisted. Flushing efforts that were initially 
instituted were not uniformly implemented at all district schools. The district considered replacing plumbing 
in four schools, but no action was taken until 2004. The reasons for the work not being done are complex 
and no one reason can be cited. Additionally, there were no clear legal mandates for lead testing and 
compliance at schools served by public water utilities. Lead problems therefore continued at the schools 
without school officials’ awareness. 

Because remedial measures were not instituted as originally planned, the public was not aware that lead 
problems existed until 2003. The public response to the problems was very strong and clear. The public 
wanted to be aware of the problems and wanted them fixed. The school district had also lost credibility 
because of the amount of time, the inactivity, and the lack of communication since problems were initially 
discovered in the early 1990s. 

The district has learned that clear, open, and timely communication is mandatory in order to restore public 
confidence. An aggressive policy of testing, remediation and disclosure has helped to bridge the gap between 
the district and the public and to restore confidence. 


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3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


111. Telling 

6. Informing the Public about Lead 

In addition to testing for lead and solving any contamination problems, a lead control program should also 
include a public information component. This section discusses public information techniques and the 
importance of developing an overall communication strategy. Helpful communication hints are provided 
along with sample public notice materials. 


6.1 Techniques for Disseminating Public Information 

EPA recommends that schools conducting a lead-in-drinking-water sampling program comply with the public 
information components of the Lead Contamination Control Act. There are two components: 

(1) Notify relevant parent, teacher, student, and employee organizations of the availability of your 
sampling program results. 

(2) Make copies of the sampling results available in your administrative offices “for inspection by the 
public, including teachers, other school personnel, and parents.’ 

Given the health effects of leadEPA advocates that any school conducting sampling for lead make public 
any test results. In addition, such schools should identify activities they are pursuing to correct any lead 
problems found. 

There are six basic public notification methods that can be applied alone or in combination to communicate 
lead-in-drinking-water issues and the meaning of your sampling program results. 

You should choose the method(s) that best suits your particular situation and/or protocol. Remember, you 
should not provide sampling program results to the public without also providing a basis for interpreting and 
understanding the significance of those results. All materials should be culturally and linguistically appropriate. 

• Press Release: A press release in the local newspaper can potentially inform a broad range of the 
public of lead in drinking water issues and the results of your sampling program. It is important that 
the release inform readers of how to obtain the sampling results and other lead in drinking water 
information and perhaps even include the phone number of an informed and available facility official. 

• Letters/Fliers: Letters or fliers represent the most direct and effective method of communicating lead 
in drinking water activities to parents/guardians and other members of your school or building 
community. The letters and fliers should be mailed directly. 

• Mailbox or Paycheck Stuffers: Mailbox and paycheck stuffers represent the most direct and effective 
method of communicating lead in drinking water activities to school employees. Stuffers would 
contain much the same information as that contained in a press release or letter/flier. 

• Staff Newsletter: A notice contained in a staff newsletter is another option for directly and effectively 
communicating information about the lead program to employees. 


64 









3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Presentations: Providing presentations at facility-related meetings is another effective means of 
communication. Relevant events for schools include meetings of parent-teacher organizations, faculty, 
and the school board. 

Email and Web sites: Electronic communications are convenient for many parents, especially those 
who work during the school day. Web sites can be updated frequently to quickly convey new 
information. Email provides a quick, easy method for parents to ask questions, but responses must be 
timely to be effective. 


6.2 The Components of an Effective General Communication Strategy 

Lead in drinking water can be an emotional and sensitive issue, especially for parents who are concerned about 
their children’s health. As a result, you should not view communication and outreach activities as stand-alone 
or final efforts, but rather as a part of an overall or general communication strategy. 

The purpose of a general communication strategy is to provide the means for addressing questions from 
members of your facility’s community and also to provide ongoing, up-to-date information regarding your 
sampling efforts. Ideally, you should designate a single spokesperson or special task force to interact with the public 
since it is important that your message remain consistent. 

The issues to be addressed as part of a communication strategy include: 

• Participants 

• Timing for delivery 

• Content of the message 

• Methods and manner of communication. 


6.3 Participants 

Overall, there are six primary players or interests involved in the control of lead in drinking water: 

(1) Your School Community: School employees, students, and parents should be informed and involved 
from the beginning of the process. Interested employees, students, and parent volunteers can help 
address the issue and ensure safe drinking water at your school. 

(2) Building Community: The building community consists of those users of the facility who would be 
most affected by lead in drinking water problems (i.e., students, teachers and other employees, school 
boards and community groups who use the facility). Members of the school and building community 
should be the primary targets of any general communication activities. 

(3) Local Health Community: Local health officials, such as health officers, sanitarians, and nurses, can 
help you understand potential health risks associated with elevated lead levels in drinking water. 

(4) Larger Community: The local and regional media can serve as a conduit for information reaching a 
larger local community. It is important that you be prepared to generate accurate news releases. Also, 
your spokesperson or task force should be prepared to respond to interview requests with accurate and 
consistent information. 


65 




3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


(5) States and EPA Regions: State drinking water programs and EPA Regional offices are responsible for 
ensuring that public water suppliers comply with the state and federal regulations regarding lead in 
drinking water. States or EPA may be able to provide guidance or technical assistance in 
communication strategies, health risks, and other sources of lead. 

(6) Drinking Water Community: Public water suppliers comprise the regulated drinking water 
community, and they are responsible for complying with all national and state drinking water 
standards for lead. This means that they must ensure that the water they deliver is non-corrosive, 
contains minimal amounts of lead, and will not result in significant lead-leaching from plumbing in 
individual homes and buildings. 


6.4 Timing 

The timing of your communication activities is very important. Whenever public health risks are involved, 
public communication efforts are less complicated and generate less conflict if those potentially affected are 
notified in advance of important issues and events. At a minimum, EPA recommends that you provide 
information to members of the local school community and the larger community (if deemed necessary) at 
the following three times. 

(1) Before your lead in drinking water sampling program begins. 

(2) In response to periodic interest. 

(3) After you obtain the results of testing, when/if you decide upon corrective measures, or if no corrective 
measure are required because the lead levels are low. 


6.5 Content 

Your communication messages should consist of the following information: 

(1) Details about the nature of your drinking water lead control program. 

(2) The results of your sampling program and your plans for correcting any identified problems. 

(3) Information on the public health effects and risks posed by lead in drinking water and the significance 
of lead in drinking water versus other sources such as food, air, dust, and soil. 

(4) The availability of general lead in drinking water information resources and the availability of the 
detailed sampling results for your facility. 

(3) How and where individuals may seek blood-lead level testing if they are concerned. 

(6) Recommend consultation with a physician if further assistance is needed. 

(7) How families can increase their awareness of exposure in their home and elsewhere. 


6.6 Methods and Manner of Communication 

The communication methods that can be used for your general communication strategy are largely the same as 
those described earlier and, thus, need not differ from communication activities common to school operations 
(i.e., meeting presentations, press releases, mailbox/paycheck stuffers, and letters to staff and parents). Ifyour 
school has a large community of non-English speakers you should provide information in other languages, as 
appropriate, or provide a contact name for non-English speakers to get more information. 


66 





3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Additional methods unique to your lead control program may include: 

(1) Creating an information center located at a convenient place in the facility such as a library or break 
room. 

(2) Creating a task force with representatives from the community. 

(3) Making available a list of laboratories that are state-certified to test home water for lead and other 
contaminants. 

(4) (For schools) encouraging classroom science activities that focus on drinking water quality. (Contact 
EPA’s Safe Drinking Water Hotline 1-800-426-4791— see Appendix B and C — for information on 
organizations that have such science activities). 

The following list contains some hints for effective communication: 

(1) Take the initiative in providing information to your community (it is important to do so before the 
media does it for you). When public health risks are involved, especially with respect to children, 
vague or incorrect information can be worse than no information at all. 

(2) Be a good and reliable source of information. That is, provide honest, accurate, and comprehensive 
information in every necessary area. 

(3) Always speak with one voice (i.e., designate points of contact — preferably one person — to respond to 
parents and the media). 

(4) Anticipate likely questions from members of the local community, including civic organizations and 
the media, and prepare answers. Each member of the community may have a different concern or 
viewpoint on the subject of lead testing. 

(5) Be positive, proactive, and forthcoming when working with the media. If you work together in a 
cordial manner, your communication efforts are likely to be less complex. 

(6) Keep members of the building community up-to-date as important events and information on your 
lead testing program unfold. 


6.7 Sample Public Notice Materials 

Exhibit 6.1 contains a sample public notification letter that could be used and adapted to communicate lead 
testing information. Exhibit 6.2 is a sample press release for local media that could also be used or adapted. 
Exhibit 6.3 is a sample article that could be published in a school newsletter. 


67 




3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Exhibit 6.1: Sample Public Notice Letter 


(Date) 

Anytown School Department 
Anytown, USA 00000-0000 

Dear Anytown School Community: 

Our school system is committed to protecting student, teacher, and staff health. To protect our community, (Anytown 
School District) tests our schools' drinking water for lead. 

Why Test School Drinking Water for Lead? 

High levels of lead in drinking water can cause health problems. Lead is most dangerous for pregnant women, infants, 
and children under 6 years old. Exposure to high levels of lead during pregnancy contributes to low birth weight and 
developmental delays in infants. In young children, lead exposure can lower IQ levels, affect hearing, reduce attention 
span, and hurt school performance. At very high levels, lead can even cause brain damage. 

To protect public health, the U.S. Environmental Protection Agency (EPA) suggests that schools and day care facilities 
test their drinking water for lead. If lead is found at any water outlet at levels above 20 parts per billion (ppb), EPA 
recommends taking action to reduce the lead. 

Is Our School's Drinking Water Safe? 

Yes, our schools' water is safe. Anytown School District tested our drinking water for lead. Of the (number) water 
samples we tested, only (number) showed lead levels above the 20 ppb mark. In other words, (percentage) of the 
water outlets tested did not have any lead problems. 

The first outlet with high lead levels was a drinking water fountain/bubbler at (Anytown High School) . We identified 
the source of the lead so we could fix the problem. The faucet for this drinking water fountain/bubbler was made of 
lead parts. (Lead was often used in plumbing materials until it was banned in 1986). We replaced the part with a lead- 
free faucet. Then we tested the water again and found the problem was fixed. 

The second outlet with high lead levels was a faucet in the kitchen of (Anytown Elementary School) . We found the 
source of the lead was a pipe that brings water to the faucet. We replaced the pipe with lead-free pipe. Then we tested 
the water again and found the problem was fixed. 

While we sampled the schools' water, we provided bottled water for all students and staff. When we found high lead 
levels at (two) water outlets, we made sure no one used those outlets until we had fixed the lead problems. 

How Can I Learn More? 

You can see a copy of all of our water testing results at the school district's central office, which is open Monday to 
Friday from ( 9:00 am to 5:00 pm) and on our Web site at ( www.anytownschools.k12.us) . For more information about 
water quality in our schools, please contact ( John Doe) at ( Anytown School District. 555-2233) . For information about 
water quality and sampling for lead at home, contact your local water supplier or state drinking water agency. 

Sincerely, 

(Fred Frank ) 

Superintendent of Schools 

Note: If your school district cannot immediately fix elevated lead levels, we encourage you to send this notice without 
delay. In that case, describe the interim measures you will take to provide safe drinking water until the problem can be 
addressed and the reason for the delay in a implementing a permanent solution. 


68 




















3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Exhibit 6.2: Sample Press Release for Local Media 


Anytown School Department 
One School Street 
Anytown, USA 00000-0000 
Contact: Fred Frank, Superintendent 

FOR IMMEDIATE RELEASE 

News Release 

Lead Levels in School Drinking Water Meet Federal Guidelines 

Anytown, USA, April xx, 2005... The Anytown School Department announced today that recent tests of drinking 
water in the town's schools indicate that lead levels meet federal guidelines. Although lead was initially detected 
above the recommended level at one drinking water outlet in an elementary school and at one outlet in a senior high 
school, lead levels were reduced to acceptable levels following replacement of these outlets. 

In making the announcement, School Superintendent Fred Frank stated, "We are pleased that the testing program 
identified only two drinking water outlets with elevated lead levels. Both outlets have since been replaced." 

The School Department conducted the testing program to make sure that drinking water in the school system is 
safe for children and school staff. Water with high lead levels can contribute to negative health effects, especially in 
young children. 

The testing was conducted in January by school personnel following federal and state guidelines. Samples from 
various locations in each of the schools were sent to a state-certified laboratory for analysis. The laboratory results 
were received by the School Department last week. 

Information about the lead testing program, including the laboratory results, can be found at the School 
Department office at the above address, weekdays between 8:30 a.m. and 4:30 p.m. 

STOP 


69 




3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Exhibit 6.3: Sample Newsletter Article 


Anvtown School District Conducts Sampling for Lead in Drinking Water 

Why was Testing Conducted? 

Schools that receive water from a public water system, such as our district, are not required by state or federal 
regulations to conduct testing for lead in their drinking water. The Environmental Protection Agency (EPA) requires 
our public water system to provide water to our school that is minimally corrosive. However, some school districts in 
other locations have found that water samples from their drinking water fixtures have contained relatively high levels 
of lead. The lead was found to come from the plumbing inside the schools, including fittings, solder, water coolers or 
water faucets. Because of this information, the Anvtown School District decided that testing would be in the best 
interests of the children, parents, faculty and other citizens served by our district. 

Health Effects of Lead 


The EPA has determined that lead in drinking water is a health concern at certain levels of exposure. Lead is found 
throughout the environment in lead-based paint, air, soil, household dust, food, certain types of pottery porcelain and 
pewter, and water. Lead can pose a significant risk to your health if too much of it enters your body. Lead builds up in 
the body over many years and can cause damage to the brain, red blood cells and kidneys. The greatest risk is to 
young children and pregnant women. Amounts of lead that will not hurt adults can slow down normal mental and 
physical development of growing bodies. In addition, a child at play often comes into contact with sources of lead 
contamination - like dirt and dust - that rarely affect an adult. It is important to wash children's hands and toys often, 
and to try to make sure they only put food in their mouths. 

How Lead Enters our Water 


Lead is unusual among drinking water contaminants in that it seldom occurs naturally in water supplies like 
groundwater, rivers and lakes. Lead enters drinking water primarily as a result of the corrosion, or wearing away, of 
materials containing lead in the water distribution system and in building plumbing. These materials include lead- 
based solder used to join copper pipe, brass, and chrome-plated brass faucets. In 1986, Congress banned the use of 
lead solder containing greater than 0.2% lead, and restricted the lead content of faucets, pipes and other plumbing 
materials. However, even the lead in plumbing materials meeting these new requirements is subject to corrosion. 
When water stands in lead pipes or plumbing systems containing lead for several hours or more, the lead may dissolve 
into the drinking water. This means the first water drawn from the tap in the morning may contain fairly high levels of 
lead. 

Lead in Drinking Water 

Lead in drinking water, although rarely the sole cause of lead poisoning, can significantly increase a person's total lead 
exposure, particularly the exposure of children under the age of 6. EPA estimates that drinking water can make up 20% 
or more of a person's total exposure to lead. 

Results of our Testing 

Following instructions given in an EPA guidance document especially designed for schools, we completed a plumbing 
profile for each of the buildings within the Anvtown School District. Through this effort, we identified and tested 

those drinking water outlets most likely to have high levels of lead. Of the_samples taken, all but_tested 

well below EPA's recommended level of 20 ppb for lead. 

The first outlet that tested high for lead was a drinking water fountain (bubbler) at Kennedy High School. After follow¬ 
up testing was conducted, it was determined that the faucet (bubbler head) was the source of the lead contamination. 
The faucet was replaced with a lead-free faucet and retested. Follow-up test results revealed lead levels well below 
EPA's recommended level. 

(Continued on next page) 


70 
















3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


(Continued from previous page) 

The second outlet, in the Lincoln Elementary School, was a faucet in the kitchen that showed unacceptable lead levels 
in both initial and follow-up testing. We found the source of the lead contamination to be the pipe providing water to 
the faucet. This pipe was replaced with lead-free materials. 

During the testing period, bottled water was provided to all students at all schools to minimize the potential for lead 
exposure. Upon receiving the test results, the two outlets that tested high for lead were disconnected until they were 
replaced. 

A copy of the test results is available in our central office for inspection by the public, including students, teachers, 
other school personnel, and parents, and can be viewed between the hours of 8:30 a.m. and 4:00 p.m. For more 
information about water quality in our schools, contact John Doe at the Anvtown School Department, 555-2223. For 
information about water quality in your home or for questions about testing, contact your water supplier or drinking 
water agency. 








3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Appendix A - Glossary of Terms 


Bubbler: An outlet fixture that consists of the bubbler valve, the bubbler receptacle and all associated piping, 
valves and mounting appurtenances for attaching the fixture to a wall or mounting surface. A bubbler does 
not contain a refrigeration unit. Some bubblers are attached to central chiller units, while others are not. 

Bubbler Valve: The valve and discharge device that mounts on top of the bubbler fixture and discharges water 
for consumption. 

Chiller: A central refrigeration unit providing cold water to some types of bubblers. 

Corrosion: A dissolving and wearing away of metal caused by a chemical reaction (e.g., between water and 
the piping that the water contacts). 

Drinking Water Fountain: A fixture connected to the water supply that provides water as needed. There are 
four types of drinking water fountains: (1) bubblers without central chillers, (2) bubblers with central chillers, 
(3) water coolers, and (4) bottled water dispensers. 

Faucet (“tap”): A valved outlet device attached to a pipe that normally serves a sink or tub fixture. A faucet 
discharges hot and/or cold water for a variety of consumptive uses, including drinking, cooking, and washing. 
The term “faucet” is used interchangeably with the term “tap. ” 

Fittings: Fittings are generally static parts that are used to join sections of pipe, or to join pipe to outlet 
fixtures. 

Flux: A substance applied during soldering to facilitate the flow of solder. Flux often contains lead and can 
itself be a source of lead contamination in water. The lead-free requirements of the 1986 Safe Drinking Water 
Act Amendments require that solders and flux not contain more than 0.2 percent lead. 

Header: The main pipe in the internal plumbing system of a building. The header supplies water to lateral 
pipes. 

Lateral: A plumbing branch between a header or riser pipe and a fixture or group of fixtures. A lateral may or 
may not be looped. Where more than one fixture is served by a lateral, connecting pipes are provided between 
the fixtures and the lateral. 

Lead-free: Taken from Section 1417(d) of the Safe Drinking Water Act, this term means that solders and 
flux may not contain more than 0.2 percent lead; pipes, pipe fittings, and well pumps may not contain more 
than 8.0 percent lead; and outlet plumbing fittings and fixtures must meet standards established under the lead 
leaching requirements of section 1417(e) of the Safe Drinking Water Act. 

Outlet: A location where water may be accessed for consumption such as a drinking fountain, water faucet, or 
tap. 


72 


Passivation: A corrosion control technique that causes the pipe materials to create metal-hydroxide-carbonate 
compounds that form a film on the pipe wall to protect the pipe. 







3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Potable Water Pipes: The pipes in a distribution system and in a building which carry water intended for 
human consumption. 

Public Water System: Any water system that has 1 5 or more service connections and is in operation at least 
60 days per year or any water system serving 25 or more persons daily at least 60 days per year. 

Riser: The vertical pipe that carries water from one floor to another. 

Sediment: Matter from piping or other water conveyance device that settles to the bottom of the water in the 
apparatus. If lead components are used in plumbing materials, lead sediments may form and result in elevated 
water lead levels. 

Service Connection: The pipe that carries tap water from the public water main to a building. In the past, 
these were often comprised of lead materials. 

Source Water: Untreated water from streams, rivers, lakes, or underground aquifers that is used to supply 
private wells and public drinking water. 

Solder: A metallic compound used to seal the joints between pipes. Until 1988, solder containing up to 50% 
lead was legally used in potable water plumbing. Lead-free solders, which can contain up to 0.2% lead, often 
contain one or more of the following metals: antimony, tin, copper or silver. Several alloys are available that 
melt and flow in a manner similar to lead solder. 

Valves: Valves are any of numerous mechanical devices by which the flow of water may be started, stopped, 
or regulated by a movable part that opens, shuts, or partially obstructs one or more ports of passageway. 

Water Cooler: Any mechanical device affixed to drinking water supply plumbing that actively cools water for 
human consumption. The reservoir can consist of a small tank or a pipe coil. 


73 



3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Appendix B - Publication List 

Web Site Publications* 

(1) *Actions You Can Take To Reduce Lead in Drinking Water. Web site publication. US EPA 810-F-93- 
001. June 1993. http://www.epa.gov/safewater/lead/leadlactsheet.html 

(2) Commonly Asked Questions: Section 1417 of the Safe Drinking Water Act and the NST Standard. US 
EPA. http://www.epa.gov/safewater/standard/plumbing.html 

(3) Consumer Fact Sheet on: Lead. Web site article. US EPA. http.7/www.epa.gov/safewater/dwh/c-ioc/ 
lead.html 

(4) Decision Tree for Pre-Sampling (at Schools). Web site article. US EPA. http://www.epa.gov/safewater/ 
schools 

(3) *Fact Sheet - Lead Reduction Plan - EPA Activities to Improve Implementation of the Lead and Copper 
Rule. Web site publication. US EPA 810-F-05-001. March 2003. http://www.epa.gov/safewater/lcrmr/ 
reductionplan ls.html 


(6) Frequently Asked Questions. Web site article. National Sanitation Foundation (NSF). http:// 
www.nsf.org/business/water distribution/dwa usepa.asp 


(7) *Is There Lead in the Drinking Water? Web site publication. US EPA 903-F-01-002. April 2002. 
http://www.epa.gov/safewater/lead/pdfs/v2final.pdf 


(8) *Lead Contamination Control Act (pamphlet). Web site article. Web site publication. US EPA 570/9- 
89-AAA. July 1989. http://www.epa.gov/safewater/lead/pdfs/epalccapamphletl989.pdf 


(9) 


Lead Contamination Control Act (statute). Web site article. Government Printing Office. January 2004. 
http://www.access.gpo.gov/uscode/title42/chapter6a subchapterxii partf .html 


(10) *Lead in Drinking Water in Schools and Non-Residential Buildings. Web site publication. US EPA 
812-B-94-002. (April 1994 version of this document.) 


74 






















3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


(11 )Lead in Schools and Day Care Centers. Web site article. US EPA.) http://www.epa.gov/safewater/lead/ 
schoolanddccs.htm 


(12) Mechanical Plumbing System Components. Web site article. Listing of approved components. NSE 
http://www.nsforg/business/mechanical plumbing/index.asp?program=MechanicalPluSysCom 


(13 ) National Lead Information Center - Document Request Site. 
nlicdocs.htm 


US EPA. http://www.epa.gov/lead/ 


(14) Post-Remediation Sampling. Web site article.(after replacement of fixtures, pipe, fittings, etc.). US EPA. 
http://www.epa.gov/safewater/lead/passivation.htm 


(15) Testing Schools and Day Care Centers for Lead in Drinking Water. Web site article. US EPA. http:// 
www.epa.gov/safewater/lead/testing.htm 


(16) *Lead Contamination Control Act (P.L. 100-572 - federal statute) and supporting documents. House 
Document Room, House of Representatives. Washington, DC 20515. (202) 225-3456. 


(17) ^Sampling for Lead in Drinking Water in Nursery Schools and Day Care Facilities (booklet). US EPA 
812-B-94-003. April 1994. 


(18) *The Lead Ban: Preventing the Use of Lead in Public Water Systems and Plumbing Used for Drinking 
Water (pamphlet on the federal lead ban). US EPA 570/9-89-BBB. August 1989. 

* Also available in hard copy through the National Drinking Water Hotline. See below. 

Hard Copy Publications 


EPA National Sale Drinking Water Hotline 
(800) 426-4791 

Hotline operates Monday through Friday, 
except federal holidays. 


75 












3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Appendix C - Resources 

Safe Drinking Water Hotline 1-800-426-4791 

Healthy School Environments 

Healthy School Environments 

This web site is designed to provide one-stop access to the many programs and resources available to help 
prevent and resolve environmental issues in schools, http://www.epa.gov/schools/ 

Department of Education Safe and Drug Free Schools 

This Department of Education web site offers a collection of links and resources on various school health and 
safety topics, http://www.ed.gov/admins/lead/safety/edpicks.ihtml?src=qc 

Lead Poisoning Prevention 

Lead Poison Prevention 

EPA’s Lead Awareness Program designs outreach activities and educational materials, awards grants, and manages 
a toll-free hotline to help parents, home owners, and lead professionals learn what they can do to protect their 
families, and themselves, from the dangers of lead, http://www.epa.gov/lead/ 

The Centers for Disease Control Childhood Lead Poisoning Prevention Program 

The Lead Contamination Control Act of 1988 authorized the Centers for Disease Control and Prevention 

(CDC) to initiate program efforts to eliminate childhood lead poisoning in the United States. Visit this web site 

for information on partnerships, publications, and various other materials addressing lead poison prevention. 

http://www.cdc.gov/nceh/lead/lead.htm 

National Lead Information Center (NLIC) 

The National Lead Information Center (NLIC) provides the general public and professionals with information 
about lead hazards and their prevention. NLIC operates under a contract with the U.S. Environmental 
Protection Agency (EPA), with funding from EPA, the Centers for Disease Control and Prevention, and the 
Department of Housing and Urban Development. (1-800-424-LEAD [5323]). http://www.epa.gov/lead/ 
nlic.htm 


Accredited Certification Programs: 

American National Standards Institute: list of accredited plumbing and other product certification programs. 
www.ansi.org/public/ca/ansi cp.html 

The current companies/organizations with NSF 61 plumbing component certification programs accredited by 
ANSI: 

National Sanitation Foundation: Also provides information on the standards that it has issued. 
www.nsf.org 

Underwriters Laboratories, www.ul.com 

International Association of Plumbing & Mechanical Officials, Research & Testing, Inc. 
www.iapmo.org/rnt/index.html 


76 


Canadian Standards Association International, www.csa.ca 
Truesdail Laboratories, www.truesdail.com 


















3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Appendix D - List of State Drinking Water Programs 


Alabama 

Mr. Ed Hughes, Chief 

Drinking Water Branch 

Dept, of Environmental Management 

P.O. Box 301463 

Montgomery, AL 36130-1463 

Phone: 334-271-7774 

Fax: 334-279-3031 

E-mail: ekh@adem.state.al.us 

Alaska 

Dr. James Weise, Manager 
Drinking Water Program 
Division of Environmental Health 
Alaska Dept, of Environmental Conservation 
555 Cordova St. 

Anchorage, AK 99501 
Phone: 907-269-7647 
Fax: 907-269-7655 

E-mail: james_weise@dec. state,ak.us 

American Samoa 

Ms. Sheila Wiegman, Environmental 

Coordinator 

American Samoa 

Environmental Protection Agency 

Office of the Governor 

Pago Pago, AS 96799 

Phone: 684-633-2304 

Fax: 684-633-5801 

Arizona 

Mr. John Calkins 

Drinking Water Section 

Arizona Dept, of Environmental Quality 

1110W. Washington St. 

Phoenix, AZ 85007 
Phone: 602-771-4617 
Fax: 602-771-4634 
E-mail: calkins.john@azdeq.gov 


Arkansas 

Mr. Harold R. Seifert, P.E., Director 
Division of Engineering 
Arkansas Department of Health 
4815 West Markham Street 
Mail Slot 37 

Little Rock, AR 72205-3867 
Phone: 501-661-2623 
Fax: 501-661-2032 

E-mail: hseifert@HealthyArkansas.com 

California 

Dr. David P. Spath, Chief 
Division of Drinking Water 
and Environmental Management 
California Dept, of Health Services 
PO. Box 997413 
Sacramento, CA 95899-7413 
Phone: 916-449-5582 
Fax:916-449-5575 
E-mail: DSpath@dhs.ca.gov 

Colorado 

Mr. Chet Pauls, Manager 

Drinking Water Program 

Water Quality Control Division 

Colorado Dept, of Public Health and 

Environment 

WQCD-DW-B2 

4300 Cherry Creek Drive, South 

Denver, CO 80246-1530 

Phone: 303-692-3610 

Fax: 303-782-0390 

E-mail: chester.pauls@state.co.us 


77 








3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Connecticut 

Dr. Gerald R. Iwan, Director 
Drinking Water Division 
Connecticut Dept, of Public Health 
410 Capitol Ave. MS-51 WAT 
P.O. Box 340308 
Hartford, CT 06134-0308 
Phone: 860-509-7333 
Fax: 860-509-7359 
E-mail: gerald.iwan@po.state.ct.us 

Delaware 

Mr. Edward G. Hallock, Program 

Administrator 

Office of Drinking Water 

Division of Public Health 

Delaware Health and Social Services 

Blue Hen Corporate Center, Suite 203 

655 Bay Road 

Dover, DE 19901 

Phone: 302-741-8590 

Fax: 302-741-8631 

E-mail: edward.hallock@state.de.us 

District of Columbia 

Ms. Jerusalem Bekele, Chief 
Water Quality Division 
Department of Health 
51 N Street, NE 
Washington, DC 20002 
Phone: 202-535-1603 
E-mail: jerusalem.bekele@dc.gov 

Florida 

Mr. Van R. Hoofnagle, Administrator 

Drinking Water Section 

Florida Dept, of Environmental Protection 

Twin Towers Office Building 

2600 Blair Stone Road 

Tallahassee, FL 32399-2400 

Phone:850-245-8631 

Fax: 850-245-8669 

E-mail: van.hoofnagle@dep.state.fl.us 


Georgia 

Mr. Nolton G. Johnson, Chief 
Water Resources Branch 
Environmental Protection Div., Georgia DNR 
2 Martin Luther King, Jr. Drive, S.E. 

East Tower - Suite 1362 
Atlanta, GA 30334 
Phone: 404-651-5168 
Fax: 404-651-9590 
E-mail: 

nolton_johnson@mail.dnr.state.ga.us 
*Mr. Brad Addison is Manager 
of the Drinking Water Program 
(see address above) 

Phone: 404-651-5155 

Fax: 404-651-9590 

E-mail: brad_addison@dnr.state.ga.us 

Guam 

Mr. Jesus T. Salas, Administrator 

Guam Environmental Protection Agency 

Government of Guam 

P.O. Box 22439 GMF 

Barrigada, GU 96921 

Phone: 671-472-8863 

Fax: 671-477-9402 

Hawaii 

Mr. Thomas E. Arizumi, Chief 
Environmental Management Division 
Hawaii Department of Health 
919 Ala Moana Blvd. 

Room 300 

Honolulu, HI 96814-4920 
Phone: 808-586-4304 
Fax: 808-586-4352 
E-mail: 

tarizumi@eha.health.state.hi.us 

+ Mr. Bill Wong is the Chief of 
the Safe Drinking Water Branch 
(see address above, except Room 308) 

Phone: 808-586-4258 
Fax: 808-586-4351 
E-mail: waterbill@aol.com 


78 




3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Idaho 

Mr. Lance E. Nielsen, Manager 

Drinking Water Program 

Idaho Dept, of Environmental Quality 

1410 North Hilton 

Boise, ID 83706 

Phone: 208-373-0291 

Fax: 208-373-0376 

E-mail: lance.nielsen@deq.idaho.gov 

Illinois 

Mr. Roger D. Selburg, P.E., Manager 

Division of Public Water Supplies 

Illinois EPA 

P.O. Box 19276 

Springfield, IL 62794-9276 

Phone:217-785-8653 

Fax:217-782-0075 

E-mail: roger.selburg@epa.state.il.us 

Indiana 

Mr. Patrick Carroll, Chief 

Drinking Water Branch 

Office of Water Quality 

Dept, of Environmental Management 

P.O. Box 6015 

Indianapolis, IN 46206-6015 

Phone:317-308-3281 

Fax: 317-308-3339 

E-mail: pcarroll@idem.in.gov 

Iowa 

Mr. Dennis J. Alt, Environmental Program 
Supervisor 

Water Supply Section 

Iowa Department of Natural Resources 

401 SW 7th Street, Suite M 

Des Moines, LA 50309-4611 

Phone:515-725-0275 

Fax: 515-725-0348 

E-mail: dennis.alt@dnr.state.ia.us 

*Mr. Steve Hopkins is Supervisor of 

the Water Supply Operations 

(see address above) 

Phone:515-725-0295 
Fax: 515-725-0348 

E-mail: Stephen.hopkins@dnr.state.ia.us 


Kansas 

Mr. David F. Waldo, Chief 
Public Water Supply Section 
Bureau of Water 

Kansas Dept of Health & Environment 

1000 SW Jackson St. - Suite 420 

Topeka, KS 66612-1367 

Phone: 785-296-5503 

Fax: 785-296-5509 

E-mail: dwaldo@kdhe.state.ks.us 

Kentucky 

Ms. Donna S. Marlin, Manager 

Division of Water - Drinking Water Branch 

Kentucky Dept, for Environmental Protection 

14 Reilly Road, Frankfort Ofc. Park 

Frankfort, KY 40601 

Phone: 502-564-3410 

Fax: 502-564-5105 

E-mail: donna.marlin@ky.gov 

Louisiana 

Ms. Karen Irion, Administrator 
Safe Drinking Water Program 
Center for Environmental and Health 
Services 

Office of Public Health 

Louisiana Dept, of Health and Hospitals 

6867 Blue Bonnet Blvd. 

Baton Rouge, LA 70810 
Phone: 225-765-5046 
Fax: 225-765-5040 
E-mail: Kirion@dhh.la.gov 

Maine 

Ms. Nancy Beardsley, Director 
Drinking Water Program 
Maine Department of Health and Human 
Services 

Division of Health Engineering 

11 State House Station 

Augusta, ME 04333 

Phone: 207-287-5674 

Fax: 207-287-4172 

E-mail: nancy.beardsley@maine.gov 


79 




3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Maryland 

Mr. Saeid Kasraei, Manager 
Water Supply Program 
Maryland Dept, of the Environment 
Montgomery Park Business Center 
1800 Washington Blvd. - Suite 450 
Baltimore, MD 21230-1708 
Phone:410-537-3702 
Fax:410-537-3157 
E-mail: skasraei@mde.state.md. us 

Massachusetts 

Mr. David Terry, Director 
Drinking Water Program 
Massachusetts Department of 
Environmental 
Protection 

One Winter Street, 6th Floor 

Boston, MA 02108 

Phone:617-292-5529 

Fax:617-292-5696 

E-mail: david.terry@state.ma.us 

Michigan 

Mr. James K. Cleland, P.E., Chief 
Water Bureau 

Michigan Dept. ofEnv. Quality 
P. O. Box 30630 
Lansing, MI 48909-8130 
Phone:517-241-1287 
Fax: 517-335-0889 

E-mail: clelandj@michigan.gov 

Minnesota 

Mr. Doug Mandy, Manager 
Drinking Water Protection Section 
Minnesota Department of Health 
Metro Square Building, Suite 220 
P.O. Box 64975 
St. Paul, MN 55164-0975 
Phone:651-215-0757 
Fax: 651-215-0775 

E-mail: douglas.mandy@health.state.mn.us 


Mississippi 

Mr. Keith Allen, Director 

Division of Water Supply 

Mississippi State Department of Health 

P.O. Box 1700 

570 E. Woodrow Wilson Dr. 

Jackson, MS 39215-1700 
Phone: 601-576-7518 
Fax: 601-576-7822 
E-mail: kallen@msdh.state.ms.us 

Missouri 

Mr. Ed Galbraith, Director 
Water Protection Program 
Missouri Dept of Natural Resources 
P.O. Box 176 
Jefferson City, MO 65102 
Phone: 573-751-6721 
Fax: 573-751-1146 
E-mail: ed.galbraith@dnr.mo.gov 

Montana 

Mr. Jon Dillard, Bureau Chief 
Public Water and Subdivisions Bureau 
Montana Dept, of Environmental Quality 
Box 200901 
1520 East Sixth Ave. 

Helena, MT 59620-0901 
Phone: 406-444-4071 
Fax: 406-444-1374 
E-mail: jdillard@mt.gov 

Nebraska 

Mr. Jack L. Daniel, Administrator 
Environmental Health Services Section 
Nebraska Health and Human Services 
System 

301 Centennial Mall South, 3rd Floor 

P.O. Box 95007 

Lincoln, NE 68509-5007 

Phone: 402-471-0510 

Fax: 402-471-6436 

E-mail: jack.daniel@hhss.ne.gov 


80 







3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Nevada 

Mr. Andrew Huray, Chief 
Public Health Engineering Section 
Nevada State Health Division 
1179 Fairview Drive 
Carson City, NV 89701 
Phone: 775-687-6353 
Fax: 775-687-5699 
E-mail: ahuray@nvhd.state.nv.us 

New Hampshire 

Mr. Rene Pelletier, Program Manager 

Water Supply Engineering Bureau 

Dept, of Environmental Services 

Post Office Box 95 

6 Hazen Drive 

Concord, NH 03302-0095 

Phone: 603-271-3434 

Fax: 603-271-5171 

E-mail: rpelletier@des.state.nh.us 

* Ms. Sarah Pillsbury is Drinking Water 

Administrator 

(see address above) 

Phone: 603-271-1168 

Fax: 603-271-2181 

E-mail: spillsbury@des.state.nh.us 

New Jersey 

Mr. Barker Hamill, Chief 

Bureau of Safe Drinking Water 

New Jersey Department of Environmental 

Protection 

P.O. Box 426 

Trenton, NJ 08625 

Phone: 609-292-5550 

Fax: 609-292-1654 

E-mail: barker.hamill@dep.state.nj.us 


New Mexico 

Mr. Fernando Martinez, Chief 
Drinking Water Bureau 
New Mexico Environment Department 
525 Camino De Los Marquez 
Suite 4 

Santa Fe, NM 87505 
Phone: 505-827-1400 
Fax: 505-827-7545 
E-mail: 

fernando_martinez@nmenv.state.nm.us 

New York 

Mr. Jack Dunn, Director 

Bureau of Public Water Supply Protection 

New York Department of Health 

Flanigan Square, Rm. 400 

547 River Street 

Troy, NY 12180-2216 

Phone:518-402-7650 

Fax: 518-402-7659 

E-mail: jmd02@health.state.ny.us 

North Carolina 

Ms. Jessica G. Miles, P.E., Chief 
Public Water Supply Section 
North Carolina Dept, of Env. and Natural 
Resources 

1634 Mail Service Center 

Raleigh, NC 27699-1634 

Phone:919-715-3232 

Fax:919-715-4374 

E-mail: jessica.miles@ncmail.net 

North Dakota 

Mr. Larry J. Thelen, Program Manager 

Drinking Water Program 

ND Dept, of Health 

1200 Missouri Avenue, Room 203 

P.O. Box 5520 

Bismarck, ND 58506-5520 

Phone: 701-328-5257 

Fax: 701-328-5200 

E-mail: lthelen@state.nd.us 


81 




3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Northern Mariana Islands 

Mr. John I. Castro, Director 

Division of Environmental Quality 

Commonwealth of the Northern Mariana Islands 

Post Office Box 501304 

Saipan, MP 96950-1304 

Phone: 670-664-8500 

Fax: 670-664-8540 

E-mail: deq.director@saipan.com 
*Mr. Joe M. Kaipat is the Manager of 
the Safe Drinking Water Branch 
(see address above) 

Phone: 670-664-8500 
Fax: 670-664-8540 
E-mail: joe.kaipat@saipan.com 

Ohio 

Mr. Mike G. Baker, Chief 

Division of Drinking and Ground Waters 

Ohio EPA 

Lazarus Gov’t Center 

P.O. Box 1049 

Columbus, OF! 43216-1049 

Phone: 614-644-2752 

Fax: 614-644-2909 

E-mail: mike.baker@epa.state.oh.us 

*Mr. Kirk Leifheit is Assistant Chief of 

Drinking Water in the 

Division of Drinking and Ground Waters 

(see address above) 

Phone: 614-644-2769 

Fax: 614-644-2909 

E-mail: kirk.leifheit@epa.state.oh.us 

Oklahoma 

Mr. Jon L. Craig, Director 

Water Quality Division 

Department of Environmental Quality 

707 North Robinson 

Suite 8100 

P.O. Box 1677 

Oklahoma City, OK 73101-1677 
Phone: 405-702-8100 
Fax: 405-702-8101 
E-mail: jon.craig@deq.state.ok.us 


*Mr. Mike S. Harrell is Administrator of 
the Public Water Supply Program 
(see address above) 

Phone: 405-702-8158 

Fax: 405-702-8101 

E-mail: mike.harrell@deq.state.ok.us 

Oregon 

Mr. David E. Leland, Manager 
Drinking Water Program 
Office of Public Health Systems 
Oregon Department of Human Services 
800 NE Oregon St. - Rm. 611 
Portland, OR 97232 
Phone: 503-731-4010 
Fax: 503-731-4077 
E-mail: david.e.leland@state.or.us 

Pennsylvania 

Mr. Jeffrey A. Gordon, Chief 

Division of Operations Management and Training 

Bureau of Water Standards and Facility 

Regulation 

Department of Environmental Protection 

P.O. Box 8467 

Harrisburg, PA 17105-8467 

Phone:717-772-4018 

Fax: 717-772-3249 

E-mail: jegordon@state.pa.us 

Puerto Rico 

Ms. Olga Rivera, Director 

Public Water Supply Supervision Program 

Puerto Rico Department of Health 

Office of the Secretary 

Nacional Plaza Building 

431 Ponce De Leon Ave. 

9th Floor - Suite 903 
Hato Rey, PR 00917 
Phone: 787-648-3903 
Fax: 787-758-6285 
E-mail: orivera@salud.gov.pr 


82 






3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Rhode Island 

Ms. June A. Swallow, P.E., Chief 
Office of Drinking Water Quality 
Rhode Island Department of Health 
3 Capitol Hill, Room 209 
Providence, RI 02908 
Phone: 401-222-6867 
Fax: 401-222-6953 
E-mail: junes@doh.state.ri.us 

South Carolina 

Mr. Alton C. Boozer, Chief 
Bureau of Water 

South Carolina Dept, of Health & 

Environmental Control 

2600 Bull Street 

Columbia, SC 29201 

Phone: 803-898-4259 

Fax: 803-898-3795 

E-mail: boozerac@dhec.sc.gov 

South Dakota 

Mr. Rob Kittay, Administrator 

Drinking Water Program 

Division of Environmental Regulation 

SD Dept, of Env. and Natural Resources 

523 East Capital Ave, Joe Foss Bldg 

Pierre, SD 57501-3181 

Phone: 605-773-4208 

Fax: 605-773-5286 

E-mail: rob.kittay@state.sd.us 

Tennessee 

Mr. W. David Draughon, Jr., Director 
Division of Water Supply 
Tennessee Dept, of Environment & 
Conservation 
401 Church Street 
L & C Tower, 6th Floor 
Nashville, TN 37243-1549 
Phone:615-532-0152 
Fax:615-532-0503 

E-mail: david.draughon@state.tn.us 


Texas 

Mr. E. Buck Henderson, Manager 
Public Drinking Water Section 
Water Supply Division 
Texas Commission on 
Environmental Quality 
P.O. Box 13087 (MC- 155) 

Austin, TX 78711-3087 
Phone: 512-239-0990 
Fax: 512-239-0030 
E-mail: ehenders@tceq.state.tx.us 

Utah 

Mr. Kevin W. Brown, Director 

Division of Drinking Water 

Utah Dept, of Environmental Quality 

P.O. Box 144830 

Salt Lake City, UT 84114-4830 

Phone: 801-536-4188 

Fax: 801-536-4211 

E-mail: kwbrown@utah.gov 

Vermont 

Mr. Jay L. Rutherford, P.E., Director 

Water Supply Division 

Vermont Dept, of Env. Conservation 

Old Pantry Building 

103 South Main Street 

Waterbury, VT 05671-0403 

Phone: 802-241-3434 

Fax: 802-241-3284 

E-mail: jay.rutherford@state.vt.us 

Virgin Islands 

Mr. Leonard Reed, Assistant Director 
Division of Environmental Protection 
Dept, of Planning & Natural Resources 
Wheatley Center 2 
St. Thomas, VI 00802 
Phone: 340-777-4577 
Fax: 340-774-5416 

* Mrs. Christine M. Lottes is Supervisor of Public 
Water System Supervision (PWSS) 

Dept, of Planning & Natural Resources 
Water Gut Homes 1118 
Christiansted, St. Croix, VI 00820-5065 
Phone: 340-773-0565 
Fax: 340-773-9310 





3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Virginia 

Mr. Jerry Peaks, Director 
Office of Drinking Water 
Virginia Department of Health 
109 Governor St. 

Richmond, VA 23219 

Phone: 804-864-7488 

Fax: 804-864-7320 

E-mail: jerry.peaks@vdh.viginia.gov 

Washington 

Ms. Denise Addotta Clifford, Director 

Office of Drinking Water 

WA Department of Health 

7211 Cleanwater Lane, Bldg. 9 

P.O. Box 47828 

Olympia, WA 98304-7828 

Phone: 360-236-3110 

Fax: 360-236-2253 

E-mail: denise.clifford@doh.wa.gov 

West Virginia 

Mr. Walter Ivey, Director 
Environmental Engineering Div. 

Office of Environmental Health Services 
West Virginia Dept, of Health and Human 
Services 

815 Quarrier Street, Suite 418 
Charleston, WV 25301 
Phone: 304-558-6715 
Fax: 304-558-0289 
E-mail: walterivey@wvdhhr.org 

Wisconsin 

Ms. Jill D. Jonas, Director 

Bureau of Drinking Water and Groundwater 

Wisconsin Department of Natural Resources 

P.O. Box 7921 

Madison, WI 53707 

Phone: 608-267-7545 

Fax: 608-267-7650 

E-mail: jill.jonas@dnr.state.wi.us 


Wyoming 

Mr. John Wagner, Administrator 
Water Quality 

Dept, of Environmental Quality 
Herschler Building 
4th Floor West 
Cheyenne, WY 82002 
Phone: 307-777-7055 
Fax: 307-777-5973 
E-mail: jwagne@state.wy.us 
^Wyoming’s Drinking Water Prog 
EPA Region VIII 


is managed by 


84 








3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Appendix E - Water Cooler Summary 

The Lead Contamination Control Act (LCCA), which amended the Safe Drinking Water Act, was signed into 
law on October 31, 1988 (P.L. 100-372). The potential of water coolers to supply lead to drinking water in 
schools and child care centers was a principal focus of this legislation. Specifically, the LCCA mandated that 
the Consumer Product Safety Commission (CPSC) order the repair, replacement, or recall and refund of 
drinking water coolers with lead-lined water tanks. In addition, the LCCA called for a ban on the 
manufacture or sale in interstate commerce of drinking water coolers that are not lead-free. Civil and criminal 
penalties were established under the law for violations of this ban. With respect to a water cooler that may 
come in contact with drinking water, the LCCA defined the term “lead-free” to mean: 

“not more than 8 percent lead, except that no drinking water cooler which contains any solder, flux, or storage 
tank interior surface which may come in contact with drinking water shall be considered lead-free if the solder, 
flux, or storage tank interior surface contains more than 0.2 percent lead.” 

Another component of the LCCA was the requirement that EPA publish and make available to the states a list 
of drinking water coolers, by brand and model, that are not lead-free. In addition, EPA was to publish and 
make available to the states a separate list of the brand and model of water coolers with a lead-lined tank. EPA 
is required to revise and republish these lists as new information or analyses become available. 

Based on responses to a Congressional survey in the winter of 1988, three major manufacturers, the Halsey 
Taylor Company, EBCO Manufacturing Corporation, and Sunroc Corporation, indicated that lead solder had 
been used in at least some models of their drinking water coolers. On April 10, 1988, EPA proposed in the 
Federal Register (at 34 FR 14320) lists of drinking water coolers with lead-lined tanks and coolers that are not 
lead-free. Public comments were received on the notice, and the list was revised and published on January 18, 
1990 (Part III, 55 FR 1772). See Fable E-2 for a list of water coolers and lead components. 

Prior to publication of the January 1990 list, EPA determined that Halsey Taylor was the only manufacturer 
of water coolers with lead-lined tanks. 1 Table E-l presents a listing of model numbers of the Halsey Taylor 
drinking water coolers with lead-lined tanks that had been identified by EPA as of January 18, 1990. 


1 Based upon an analysis of 22 water coolers at a US Navy facility and subsequent data obtained by EPA, EPA believes 
the most serious cooler contamination problems are associated with water coolers that have lead-lined tanks. 






3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Since the LCCA required the CPSC to order 
manufacturers of coolers with lead-lined tanks to 
repair, replace or recall and provide a refund of 
such coolers, the CPSC negotiated such an 
agreement with Halsey Taylor through a consent 
order published on June 1, 1990 (at 55 FR 
22387). The consent agreement calls on Halsey 
Taylor to provide a replacement or refund 
program that addresses all the water coolers listed 
in Table E-2 as well as “all tank-type models of 
drinking water coolers manufactured by Halsey 
Taylor, whether or not those models are included 
on the present or on a future EPA list.” Under 
the consent order, Halsey Taylor agreed to notify 
the public of the replacement and refund 
program for all tank type models. 

Currently, a company formerly associated with Halsey Taylor, Scotsman Ice Systems, has assumed 
responsibility for replacement of lead-line coolers previously marketed by Halsey Taylor. See below for the 
address of Scotsman Ice Systems. 


SPECIAL NOTE: 

Experience indicates that newly installed brass 
plumbing components containing 8 percent or less 
lead, as allowed by the SDWA, can contribute high 
lead levels to drinking water for a considerable 
period after installation. U.S. water cooler 
manufacturers have notified EPA that since 
September 1993, the components of water coolers 
that come in contact with drinking water have been 
made with non-lead alloy materials. These materials 
include stainless steel for fittings and water control 
devices, brass made of 60 percent copper and 40 
percent zinc, terillium copper, and food grade 
plastic. 


Scotsman Ice Systems 
775 Corporate Woods Parkway 
Vernon Hills, IL 60061 
PH: (800) SCOTSMAN or 800-726-8762 
PH: (847) 215-4500 


Table E-l 

Halsey Taylor Water Coolers With Lead-Lined Tanks 2 

The following six model numbers have one or more units in the model series with lead- 
lined tanks: 


WM8A WT8A 

GC10ACR GC10A 

GC5A RWM13A 

The following models and serial numbers contain lead-lined tanks: 

WM14A Serial No. 

WM14A Serial No. 

WT11A Serial No. 222650 

843034 

843006 


WT21A Serial No. 

WT21A Serial No. 

LL14A Serial No. 64346908 

64309550 

64309542 



86 


2 Based upon an analysis of 22 water coolers at a US Navy facility and subsequent data obtained by EPA, EPA believes 
the most serious cooler contamination problems are associated with water coolers that have lead-lined tanks. 



























3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Table E-2 

Water Coolers With Other Lead Components 

EBCO Manufacturing 

All pressure bubbler water coolers with shipping dates from 1962 through 1977 have a bubbler valve 
containing lead. The units contain a single, 50-50 tin-lead solder joint on the bubbler valve. Model 
numbers for coolers in this category are not available. 

The following models of pressure bubbler coolers produced from 1978 through 1981 contain one 50-50 
tin-lead solder joint each. 


CP3 

DP15W 

DPM8 

ZP 

13P 

DPM8H 

DP15M 

DP3R 

DP8A 

DP16M 

DP5S 

C10E 

PX-10 

DP7S 

DP13SM 

DP7M 

DP7MH 

DP7WMD 

WTC10 

DP13M-60 

DP14M 

CP 10-50 

CP5 

CP5M 

DP15MW 

DP3R 

DP14S 

DP20-50 

DP7SM 

DPI OX 

DP13A 

DP13A-50 

EP10F 

DP5M 

DP10F 

CP3H 

CP3-50 

DP13M 

DP3RH 

DP5F 

CP3M 

EP5F 

13PL 

DP8AH 

DP13S 

CP10 

DP20 

DP12N 

DP7WM 

DP14A-50/60 






Halsey Taylor 

1. Lead solder was used in these models of water coolers manufactured between 1978 and the last week of 1987 1 


WMA-1 

SC WT/SC WT-A 

SWA-1 

DC/DHC-1 

S3/5/10D 

BFC-4F/7F/4FS/7FS 

S300/500/100D 



2. The following coolers manufactured for Haws Drinking Faucet Company (Haws) by Halsey Taylor from November 1984 
through December 18, 1987, are not lead-free because they contain 2 tin-lead solder joints. The model designations for these 
units are as follows: 


HC8WT 

HC14F 

HC6W 

HWC7D 

HC8WTH 

HC14F 

H 

HC8W 

HC2F 

HC14WT 

HC14FL 

HC14W 

HC2FH 

HC14WTH 

HC8FL 

HC4F 

HC5F 

HC14WL 

HCBF7D 

HC4FH 

HC10F 

HC16WT 

HCBF7HO 

HC8F 

HC8FH 

HC4W 

HWC7 



If you have one of the Halsey Taylor water coolers noted in Table E-2, contact Scotsman Ice Systems (address and phone 
noted above) to learn more about the requirements surrounding their replacement and rebate program. 


87 


























































































3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Appendix F - Sample Recordkeeping Form 


Appendix F - Sample Recordkeeping Form 


Record of Sampling 


Name of Building 
Name of Sample Collector 
Contact Person for this Record 


Sample ID Number 


Circle sample type: Initial / 1 st Follow-up / 2 nJ Follow-up 



88 
































































3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Appendix G - 

Preservation of Samples and Sample Containers 

This appendix contains information pertaining to the preservation of samples and sample containers. A certified 
drinking water laboratory should be aware of these requirements. In addition, they will provide you with actual 
samplers or sample containers and instructions. The sample containers may have been prepared prior to your receipt. 

The laboratory will also specify how to handle the sample containers and when to submit them after taking your 
samples. 

In order to avoid analytical errors, pay particular attention to proper collection and handling of the sample 
before analysis. Sample containers (250 mL) should be obtained from a certified laboratory. You should not 
use other containers such as used jars or water bottles. 

Make sure the containers are kept sealed between the time of their preparation by the lab and the collection of 
the sample. This will assure that no contaminants from the outside are introduced. Preserve the sample by 
icing and promptly ship or deliver it to the laboratory. Most laboratories will provide the necessary shipping 
containers and cold packs. Upon receipt, the laboratory will acidify the sample. The sample can be held up to 
14 days prior to acidification without loss of lead through absorption, but EPA recommends that the 
laboratories receive the samples as soon as possible. 

For more detailed information, refer to the following documents: 

Methods for the Determination of Metals in Environmental Samples. EPA/600/4-94/111. May 1994 
(available from the National Technical Information Service, Pub. No. PB95-125472 (703) 487-4650). 

Manual for the Certification of Laboratories Analyzing Drinking Water. US EPA 815-B-97-001. March 
1997 (available from the National Technical Information Service (703) 487-4650). 

Standard Methods for the Examination of Water and Wastewater, 2(f h Edition. Co-published by the 
American Public Health Association, the Water Environment Federation, and the American Water Works 
Association. 1998 (available from the American Water Works Association, ISBN # 0-87553-235-7, Catalog 
#10079). 


89 











3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Appendix H - 

Example Scenarios for Water Sample Results 


Service Connection Sampling (See Exhibit 4.3) 

Examples: 

• Sample 1S (20 ppb) exceeds Sample 1 M (5 ppb) = 15 ppb of lead is contributed from the service connection; the 
lead amount in the main (Sample 1 M) does not exceed 5 ppb; therefore, you may want to check for a lead sevice 
line or gooseneck depending upon results of lead testing at other outlets in the building; if you reduce lead at the 
connection, lead levels may be reduced throughout the remainder of the building. 

• Sample 1M is 10 ppb and Sample 1S is 10 ppb = very little lead is contributed from the service line; source of lead 
is most likely the water main. 

• Sample 1S (7 ppb) and Sample 1 M (6 ppb) are close to 5 ppb = very little lead (1 ppb) is being picked up in the 
water from the service line or the distribution main; very little lead is contributed from the source water; if other 
outlets show significantly higher lead levels, the source of the contamination is the interior plumbing and/or the 
outlets themselves. 


Drinking Water Fountain without Central Chiller (See Exhibit 4.4) 

Example: 

• Sample 1A (31 ppb) exceeds Sample 2A (7 ppb) = 24 ppb of lead is contributed from the bubbler. 

• Sample 2A (7 ppb) does not significantly exceed 5 ppb = very little lead (2 ppb) is being picked up from the 
plumbing upstream from the bubbler; the majority of the lead in the water is contributed from the bubbler. 

• Sample 2A (7 ppb) does not exceed 20 ppb = sampling from header or loop supplying water to the lateral is not 
necessary. 

Possible Solution: Replace fixture, valves, or fittings on bubbler with lead-free device (ensure compliance with the 
NSF standards for any fixtures you intend to purchase); retest water for lead after new materials installed. 


90 












3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Drinking Water Fountain with Central Chiller (See Exhibits 4.4 and 4.9) 

Example 1: 

• Sample 1A (25 ppb) exceeds Sample 2A (3 ppb) = 22 ppb of lead is contributed from the bubbler. 

• Sample 2A (3 ppb) is close to 5 ppb = very little lead is being picked up from the plumbing upstream from the 
bubbler; the majority or all of the lead is contributed from the bubbler. 

Possible Solution: Replace bubbler valve, fittings and/or fixture with lead-free materials (request results of lead 
leaching studies from manufacturers of brass products before purchasing to ensure that harmful amounts of lead will 
not be leached); retest water once new materials installed. 

Example 2: 

• Sample 1A (38 ppb) exceeds Sample 2A (21 ppb) = 17 ppb of lead is contributed from the bubbler. 

• Sample 2A (21 ppb) significantly exceeds 5 ppb = about 21 ppb of lead is being contributed from the plumbing 
upstream from the bubbler. 

• Sample 2A (21 ppb) exceeds 20 ppb = sampling from the chiller unit supplying the water to the lateral is 
necessary to locate the source of the contamination (see instructions and examples below for sampling chiller 
units). 

Example 3: 

• Sample 2A (21 ppb) exceeds Sample 2K (10 ppb) = 11 ppb of lead is contributed from the plumbing supplying 
the water from the chiller to the bubbler. 

• Sample 2K (10 ppb) exceeds Sample 1K (4 ppb) = a portion of the lead (6 ppb) may be coming from the chiller; 
check for and remove any debris and sludge in the chiller unit; flush the unit, and resample the water. 

• Sample 1K (4 ppb) does not exceed 20 ppb = additional sampling from the distribution system supplying water 
to the chiller is not necessary. 

• Sample 1K (4 ppb) is very close to 5 ppb = very little lead is picked up from the plumbing upstream from the 
chiller; the majority or all of the lead in the water can be attributed to the chiller and the plumbing downstream 
from the chiller. 

Possible Solutions: Flush the chiller unit and plumbing; if lead levels are still high, replace plumbing supplying water 
from the chiller to the bubbler; replace the bubbler fixture, fittings, and valves with lead-free materials; and clean 
sediment and debris from chiller unit. Retest water for lead once changes have been made. If the lead levels after 
initial flushing are low, clean any sediment and debris from the chiller, and resample the chiller monthly for 3 months. 
If the lead levels increase, the additional remediation measures listed immediately above are probably necessary to 
reduce lead risks. If the levels remain low, routine annual cleaning of sediment and debris and routine monitoring at 
the same frequency as other sites is recommended . 

Example 4: 

• Sample 2A (45 ppb) exceeds Sample 2K (28 ppb) = 17 ppb of lead is being contributed from the plumbing 
supplying water from the chiller to the bubbler. 

• Sample 2K (28 ppb) exceeds Sample 1K (21 ppb) = 7 ppb of lead is contributed by the chiller. 

• Sample 1K (21 ppb) exceeds 20 ppb = additional sampling from the distribution system supplying water to the 
chiller is necessary to locate the source of the contamination (see Exhibit 4.9 on Sampling Interior Plumbing for 
instructions). 

Possible Solution: Lead levels are clearly elevated at all sample sites. It appears that multiple sources of lead are 
contributing to the problem. Retesting may help locate sources of lead, but it appears that the solution includes 
replacement of upstream plumbing; the bubbler fixture, valves, and fittings with lead-free materials; and cleaning the 
sediment and debris from the chiller. Retest water for lead after changes have been made. If levels are still elevated, 
replacement of the chiller may be necessary. 


91 





3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Drinking Water Fountain (Water Coolers) (See Exhibit 4.5) 

Example 1: 

• Sample 1C (54 ppb) = the plumbing upstream from the cooler and/or the water cooler is contributing lead. 

• Sample 3C (40 ppb) exceeds Sample 2C (5 ppb) = the water cooler is contributing 35 ppb of lead. 

• Sample 3C (40 ppb) exceeds Sample 2C (5 ppb) and Sample 1C (54 ppb) exceeds Sample 3C (40 ppb) = the 
plumbing directly upstream from the cooler is contributing 14 ppb of lead. 

• Sample 2C (5 ppb) is less than 10 ppb and Sample 2C is less than Sample 1C (54 ppb) and Sample 3C (40 ppb) = 
the source of lead is not sediments contained in the cooler storage tank, screens, or plumbing upstream from the 
cooler. 

Possible Solutions: Replace the cooler with one that contains lead-free components, and retest the water or find an 
alternative lead-free drinking water source; locate source of lead from plumbing and eliminate it (routine flushing is 
not applicable as a potential remedy for water coolers - see discussion of this issue in Sections 5.2 and 5.3 of this 
guidance document for further information). 

Example 2: 

• Samples 1C (44 ppb), 3C (42 ppb) and 2C (41 ppb) are approximately equal = the cooler is not the likely source 
of lead. 

• Sample 1C (44 ppb) exceeds Sample 3C (42 ppb) and Sample 3C and Sample 2C (41 ppb) are close = the 
plumbing upstream from the cooler is contributing lead to the water. 

• Samples 1C (44 ppb), 3C (42 ppb) and 2C (41 ppb) are approximately equal = the source of lead is not likely 
sediments contained in the cooler storage tank or screens. 

• Sample 4C (43 ppb) significantly exceeds 5 ppb = the source of lead is the plumbing upstream from the cooler. 

Possible Solutions: Replace the plumbing upstream between the header and cooler with lead-free materials and retest 
the water. If the water continues to test high, the header, service connection and/or public water supply may be the 
problem. An evaluation should be made as soon as possible to determine the source of the lead, and other outlets 
should be tested immediately if not already done. Remember that flushing is not recommended as a practical remedy 
for water coolers. 


Bottled Water Dispensers (See Exhibit 4.6) 

Example 1: 

• Sample 1D (23 ppb) exceeds Sample 2D (5 ppb) = 18 ppb of lead is contributed from the dispenser unit. 

Possible Solution: Replace dispenser unit with one that is made of lead-free materials and retest. 

Example 2: 

• Sample 1D (24 ppb) and Sample 2D (23 ppb) are close = the source of lead is the bottled water. 

Possible Solutions: Purchase another type of bottled water for which the distributor provides written assurance that 
lead levels do not exceed federal and state lead standards, or find other alternative lead-free water source. Retest after 
any remedy has been employed. 













3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Ice Making Machines (See Exhibit 4.7) 

Example 1: 

• Sample 1 E is 22 ppb and Sample 2E (6 ppb) is close to 5 ppb = source of the lead (16 ppb) is the ice maker. 

Possible Solutions: Replace plumbing components in ice maker with lead-free materials; clean debris from plumbing 
and screen at inlet to ice maker; replace with lead-free ice maker; retest after any remedy has been employed. 

Example 2: 

• Sample 1E = 22 ppb and Sample 2E (21 ppb) significantly exceeds 5 ppb = lead is contributed from the 
plumbing upstream from the ice maker. 

• Sample 2E (21 ppb) exceeds 20 ppb = sampling from the distribution system supplying water to the ice maker is 
recommended (see Exhibit 4.9 for instructions). 


Faucets (Taps) (See Exhibit 4.8) 

Example 1: 

• Sample 1F (39 ppb) exceeds Sample 2F (6 ppb) = 33 ppb of lead is contributed from the water faucet. 

• Sample 2F (6 ppb) is close to 5 ppb = very little lead is coming from the plumbing upstream from the faucet; the 
majority of the lead is coming from the faucet and/or the plumbing connecting the faucet to the lateral. 

Possible Solutions: Replace faucet with lead-free device (ensure compliance with the NSF standards for any fixtures 
you intend to purchase); replace plumbing connecting the faucet to the lateral with lead-free materials; flush outlet 
and connecting plumbing each day; apply point-of-use device designed to remove lead; find alternative water source 
such as bottled water or other lead-free location in the building; retest after any remedies are employed. 

Example 2: 

• Sample 1F (49 ppb) exceeds Sample 2F (25 ppb) = source of lead (24 ppb) is the water faucet and the plumbing 
upstream from the outlet (25 ppb). 

• Sample 2F (25 ppb) significantly exceeds 5 ppb = lead may be contributed from upstream from the faucet; 
evaluate lead test results conducted upstream from the faucet to ascertain potential contributions of lead from 
the upstream piping. To pinpoint location test interior plumbing (see instructions for sampling interior plumbing 
in Exhibit 4.9). 

Possible Solutions: Replace faucet with lead-free device (ensure compliance with the NSF standards for any fixtures 
you intend to purchase); replace plumbing connecting faucet to the lateral with lead-free materials; replace suspected 
portion of interior plumbing with lead-free materials; flush the outlet and interior plumbing each day; apply point-of- 
use device designed to remove lead; find alternative water source such as bottled water or water from other lead-free 
location in the building; retest after any remedies are employed. 


93 





3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


Interior Plumbing (See Exhibit 4.9) 

Example 1: 

• Sample 1G (22 ppb) exceeds 20 ppb = collect additional samples from the plumbing upstream to further 
pinpoint the source of lead (i.e., from the service line, the riser pipe, the loop, or the header supplying water to the 
lateral). 

• Sample 1G (22 ppb) significantly exceeds 5 ppb and is less than downstream site (35 ppb) = a portion of the lead 
(13 ppb) is contributed downstream from the sample site. 

• Sample 1G (22 ppb) is not similar to downstream site (35 ppb) but both exceed 20 ppb = lead is contributed 
from the lateral or from interior plumbing upstream from the lateral; possible sources of lead may be the loop, 
header, riser pipe, or service connection; further sampling is necessary. 

Possible Solution: Following the collection of additional samples from plumbing upstream to pinpoint sources of 
lead, replace plumbing with lead-free materials; retest water for lead. 

Example 2: 

• Sample 1H or 1J (23 ppb) exceeds 20 ppb = collect additional samples from the plumbing upstream supplying 
water to the loop or header; compare the results with those taken from the service line or the riser pipe that 
supplies water to the loop and/or header. 

• Sample 1 H or 1J (23 ppb) significantly exceeds 5 ppb and Sample 1 H or 1J is less than downstream site (25 ppb) 

= a small portion of the lead (2 ppb) is contributed downstream of the sample site. 

Possible Solution: Following the collection of additional samples upstream from the header or loop to pinpoint 
source of lead, replace affected plumbing with lead-free materials; retest water for lead. 

Example 3: 

• Downstream Site is 25 ppb, Service Connection Sample is 4 ppb, and Sample 1J (6 ppb) is less than 20 ppb = 
additional samples from upstream need not be collected; 21 ppb of lead is contributed from the downstream site. 

• Sample 1J (6 ppb) is not equal to downstream site (25 ppb) = source of lead is not the riser pipe or the plumbing 
and service connection upstream from the riser pipe. 

• 1J (6 ppb) is close to 5 ppb = the portion of the riser pipe and plumbing upstream from Sample Site 1J and the 
service connection are not contributing lead to the water; the source of lead is downstream of the sample site. 

Possible Solution: Following the collection of samples from interior plumbing downstream from the riser pipe and 
the affected outlet to pinpoint the source of lead, replace affected plumbing with lead-free materials; retest water for 
lead. 












Appendix I - Plumbing Profile Questionnaire 


3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 


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3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 



96 















3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 



97 











3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 



98 

















3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance 





99 









EPA 816-B-05-008 

December 2005 
Office of Water (4606) 


























LIBRARY OF CONGRESS 





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EPA816-B-05-008 

December 2005 
Office of Water (4606) 




































